the complaint is not subject to exhaustion because it seeks relief not available under the IDEA, namely compensatory and punitive damages. While the IDEA allows attorney’s fees and costs (which McCauley seek 64 (1st Cir. 2002) (“[W]e hold that plaintiffs who bring an IDEA-based claim under 42 U.S.C. § 1983, in which they seek only money damages, must exhaust the administrative process available under the IDEA as a condition precedent to entering a state or federal court.”); Covington v. Knox Cnty. School Sys., 205 F.3d 912, 917 (6th Cir. 2000) (“[W]e agree with those courts that have decided that a mere claim for money damages is not sufficient to render exhaustion of administrative remedies unnecessary.”); N.B. by D.G. v. Alachua Cnty. School Bd., 84 F.3d 1376, 1379 (11th Cir. 1996) (<HOLDING>). McCauley’s voluntary decision to remove J.M.
recognizing that issue exhaustion requirement and requirement exhaustion of remedies are different holding that exhaustion is required under the plra even if the plaintiff seeks only money damages and money damages are not available as relief 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 a plaintiff cannot avoid exhaustion simply because he or she asks for damages holding exhaustion requirement inapplicable when requiring exhaustion would be futile