20 U.S.C. § 1415(i)(3)(B), compensatory and punitive damages are not available. Bradley v. Ark. Dep’t of Educ., 301 F.3d 952, 957 (8th Cir. 2002). In Fry, the Supreme Court declined to address whether exhaustion is required “when the plaintiff complains of the denial of a FAPE, but the specific remedy she requests — here, money damages for emotional distress — is not one” the IDEA provides. Fry, 137 S.Ct. at 752 n.4, 2017 WL 685533 at *8 n.4. However, this court has noted that “the IDEA’S exhaustion requirement remains the general rule, regardless of whether the administrative process offers the particular type of relief that is being sought.” J.B., 721 F.3d at 595, quoting M.P. ex rel. K. v. Indep. School Dist. No. 721, 326 F.3d 975, 980 (8th Cir. 2003). See Muskrat, 715 F.3d at 785 (<HOLDING>); Frazier v. Fairhaven School Comm., 276 F.3d
holding exhaustion requirement inapplicable when requiring exhaustion would be futile holding that once a debtor classifies their obligations for tax purposes he or she cannot avoid the corresponding obligations or effects of this classification under the bankruptcy code holding a plaintiff cannot avoid exhaustion simply because he or she asks for damages holding that plaintiffs cannot avoid the exhaustion requirement by limiting relief to money damages because otherwise future litigants could avoid the exhaustion requirement simply by asking for relief that administrative authorities could not grant holding that release cannot be rescinded simply because plaintiff later learns she had a more serious injury