Winkelman v. Parma City School District

550 U.S. 516 (2007)

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Winkelman v. Parma City School District

United States Supreme Court
550 U.S. 516 (2007)

CS

Facts

Jacob was a child with autism who was entitled to special-education services from the Parma City School District (the district) (defendant) under the Individuals with Disabilities Education Act (IDEA). Jacob’s parents, the Winkelmans (plaintiffs) disagreed with the district’s proposed individualized education program (IEP) for Jacob and filed an administrative appeal, alleging that the district had failed to provide Jacob with a free appropriate education (FAPE). The hearing officer rejected their claim, and the Winkelmans appealed to a state-review officer. The Winkelmans again lost at that level and appealed the decision, on their own behalf and on Jacob’s behalf, in federal district court. The court held that the district had provided Jacob with a FAPE. The Winkelmans appealed the district court’s decision to the court of appeals, proceeding without counsel. The court of appeals dismissed the Winkelmans’ appeal unless they obtained counsel to represent Jacob. The United States Supreme Court granted certiorari to determine whether parents of a disabled child have independent rights under the IDEA that they may pursue pro se in federal court.

Rule of Law

Issue

Holding and Reasoning (Kennedy, J.)

Concurrence/Dissent (Scalia, J.)

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