## Facts

- Matthew Stanek, a student in a public school district, received special-education services under the Individuals with Disabilities Education Act (IDEA).
- Matthew and his parents alleged the school district failed to provide required services, discriminated based on disability, and retaliated after they asserted disability-rights claims.
- The family sued the school district, its board, the superintendent, and various teachers/administrators under IDEA, § 504 of the Rehabilitation Act, Title II of the ADA, and 42 U.S.C. § 1983.
- The action was filed in state court and removed to federal court.
- The district court dismissed most claims, including the parents’ claims for lack of standing and multiple claims against individual defendants as improper parties or inadequately pleaded.

## Issues

1. Whether parents have standing to sue in their own right for damages based on alleged denial of appropriate special-education services to their child.
2. Which defendants may be sued, and in what capacities, under IDEA, § 504, the ADA, and § 1983 in a dispute over special-education services.
3. Whether the student plausibly pleaded retaliation under § 504 and the ADA.
4. Whether claims framed under § 504, the ADA, or § 1983 must be routed through IDEA administrative procedures when they seek relief for, or are substantively about, denial of a free appropriate public education (FAPE).

## Decision

- The Seventh Circuit affirmed in part and reversed in part the dismissal order and remanded.
- The court affirmed dismissal of the student’s retaliation claims under § 504 and the ADA for failure to plead actionable adverse action and causation with sufficient specificity.
- The court held that many claims against individual employees were not viable under IDEA, § 504, and the ADA because those statutes generally provide for suit against the responsible public entity, not individuals in their personal capacities.
- The court agreed that parents could not recast the child’s alleged denial of FAPE into independent parental damages claims; parental standing existed only to the extent parents alleged their own legally cognizable injuries or enforceable procedural interests.
- The court clarified that IDEA exhaustion generally applies when the substance of § 504/ADA/§ 1983 allegations seeks relief also available under IDEA or otherwise targets denial of FAPE, and plaintiffs cannot avoid exhaustion through pleading labels.

## Legal Principles

- IDEA’s primary entitlement is the child’s right to FAPE; parents may enforce certain procedural protections but cannot automatically obtain damages for injuries that belong to the child.
- IDEA claims ordinarily lie against the school district or responsible public agency rather than individual employees, particularly in individual capacity.
- Title II of the ADA and § 504 generally authorize suits against public entities (and § 504 funding recipients), not individual employees in their personal capacities.
- Retaliation under § 504/ADA requires protected activity, an adverse action, and a plausible causal connection; conclusory allegations of causation or materially adverse action are insufficient.
- IDEA exhaustion is required when the gravamen of non-IDEA claims concerns denial of FAPE or seeks IDEA-type relief, and artful pleading does not bypass administrative procedures.

## Conclusion

The Seventh Circuit limited parental standing and individual-defendant liability in special-education litigation, affirmed dismissal of inadequately pleaded § 504/ADA retaliation claims, and reinforced that disputes substantively about denial of FAPE generally must proceed through IDEA administrative exhaustion before related federal claims may go forward.


Stanek v. St. Charles Cmty. Unit Sch. Dist. No. 303, 783 F.3d 634 (7th Cir. 2015)