## Facts

- Jacob Winkelman, a child with autism, was entitled under the Individuals with Disabilities Education Act (IDEA) to a free appropriate public education (FAPE) implemented through an individualized education program (IEP).
- Parma City School District, an IDEA-funded district, proposed an IEP placing Jacob in a public elementary school.
- Jacob’s parents, Jeff and Sandee Winkelman, disputed the adequacy of the proposed IEP and placement.
- An IDEA administrative hearing officer upheld the school district’s IEP and placement.
- The parents enrolled Jacob in a private school at their own expense and sought relief in federal court, including reimbursement and enforcement of IDEA rights.
- The parents filed the federal action without counsel, asserting claims on their own behalf and on Jacob’s behalf.

## Issues

1. Whether IDEA confers independent, enforceable rights on parents, or vests enforceable rights solely in the child.
2. Whether nonlawyer parents may prosecute IDEA claims pro se in federal court to vindicate their own IDEA rights.

## Decision

- The Supreme Court reversed the Sixth Circuit and remanded.
- The Court held that IDEA grants parents independent, enforceable rights.
- The Court held that parental rights under IDEA are not limited to procedure or reimbursement, but extend to the child’s entitlement to a FAPE.
- Because parents have their own IDEA rights, they may prosecute IDEA claims pro se in federal court on their own behalf.
- The Court did not decide whether parents may represent their child’s distinct interests pro se.

## Legal Principles

- IDEA protects the rights of both children with disabilities and their parents, and gives parents a direct role in developing, reviewing, and challenging an IEP.
- Parents are “parties” in IDEA administrative proceedings and may pursue judicial review when aggrieved by decisions concerning identification, evaluation, educational placement, or provision of FAPE.
- IDEA confers substantive rights on parents regarding the adequacy of their child’s education under the Act, not merely procedural participation rights.
- A nonlawyer parent may appear pro se in federal court to assert and enforce the parent’s own rights under IDEA, even if the case concerns the child’s FAPE.

## Conclusion

The Court held that IDEA grants parents independent, enforceable rights that include the entitlement to a FAPE for their child, and that parents therefore may litigate IDEA claims pro se in federal court to vindicate their own rights, leaving open whether they may proceed pro se solely on the child’s separate claims.


Winkelman v. Parma City Sch. Dist., 550 U.S. 516 (2007)