Winkelman v. Parma City School Dist.
Annotate this Case
550 U.S. 516 (2007)
OCTOBER TERM, 2006
WINKELMAN V. PARMA CITY SCHOOL DIST.
SUPREME COURT OF THE UNITED STATES
WINKELMAN, a minor, by and through his parents and legal guardians, WINKELMAN et ux., et al. v. PARMA CITY SCHOOL DISTRICT
certiorari to the united states court of appeals for the sixth circuit
No. 05–983. Argued February 27, 2007—Decided May 21, 2007
Respondent school district receives federal funds under the Individuals with Disabilities Education Act (Act or IDEA), so it must provide children such as petitioner Winkelmans’ son Jacob a “free appropriate public education,” 20 U. S. C. §1400(d)(1)(A), in accordance with an individualized education program (IEP) that the parents, school officials, and others develop as members of the student’s IEP Team. Regarding Jacob’s IEP as deficient, the Winkelmans unsuccessfully appealed through IDEA’s administrative review process. Proceeding without counsel, they then filed a federal-court complaint on their own behalf and on Jacob’s behalf. The District Court granted respondent judgment on the pleadings. The Sixth Circuit entered an order dismissing the Winkelmans’ subsequent appeal unless they obtained an attorney, citing Circuit precedent holding that because the right to a free appropriate public education belongs only to the child, and IDEA does not abrogate the common-law rule prohibiting nonlawyer parents from representing minor children, IDEA does not allow nonlawyer parents to proceed pro se in federal court.
1. IDEA grants parents independent, enforceable rights, which are not limited to procedural and reimbursement-related matters but encompass the entitlement to a free appropriate public education for their child. Pp. 4–17.
(a) IDEA’s text resolves the question whether parents or only children have rights under the Act. Proper interpretation requires considering the entire statutory scheme. IDEA’s goals include “ensur[ing] that all children with disabilities have available to them a free appropriate public education” and “that the rights of children with disabilities and parents of such children are protected,” 20 U. S. C. §§1400(d)(1)(A)–(B), and many of its terms mandate or otherwise describe parental involvement. Parents play “a significant role,” Schaffer v. Weast, 546 U. S. 49, 53, in the development of each child’s IEP, see §§1412(a)(4), 1414(d). They are IEP team members, §1414(d)(1)(B), and their “concerns” “for enhancing [their child’s] education” must be considered by the team, §1414(d)(3)(A)(ii). A State must, moreover, give “any party” who objects to the adequacy of the education provided, the IEP’s construction, or related matter the opportunity “to present a complaint … ,” §1415(b)(6), and engage in an administrative review process that culminates in an “impartial due process hearing,” §1415(f)(1)(A), before a hearing officer. “Any party aggrieved by the [hearing officer’s] findings and decision … [has] the right to bring a civil action with respect to the complaint.” §1415(i)(2)(A). A court or hearing officer may require a state agency “to reimburse the parents … for the cost of [private school] enrollment if … the agency had not made a free appropriate public education available to the child.” §1412(a)(10)(C)(ii). IDEA also governs when and to what extent a court may award attorney’s fees, see §1415(i)(3)(B), including an award “to a prevailing party who is the parent of a child with a disability,” §1415(i)(3)(B)(i)(I). Pp. 5–9.
(b) These various provisions accord parents independent, enforceable rights. Parents have enforceable rights at the administrative stage, and it would be inconsistent with the statutory scheme to bar them from continuing to assert those rights in federal court at the adjudication stage. Respondent argues that parental involvement is contemplated only to the extent parents represent their child’s interests, but this view is foreclosed by the Act’s provisions. The grammatical structure of IDEA’s purpose of protecting “the rights of children with disabilities and parents of such children,” §1400(d)(1)(B), would make no sense unless “rights” refers to the parents’ rights as well as the child’s. Other provisions confirm this view. See, e.g., §1415(a). Even if this Court were inclined to ignore the Act’s plain text and adopt respondent’s countertextual reading, the Court disagrees that sole purpose driving IDEA’s involvement of parents is to facilitate vindication of a child’s rights. It is not novel for parents to have a recognized legal interest in their child’s education and upbringing.
The Act’s provisions also contradict the variation on respondent’s argument that parents can be “parties aggrieved” for aspects of the hearing officer’s findings and decision relating to certain procedures and reimbursements, but not “parties aggrieved” with regard to any challenge not implicating those limited concerns. The IEP proceedings entitle parents to participate not only in the implementation of IDEA’s procedures but also in the substantive formulation of their child’s educational program. The Act also allows expansive challenge by parents of “any matter” related to the proceedings and requires that administrative resolution be based on whether the child “received a free appropriate public education,” §§1415(f)(3(E), with judicial review to follow. The text and structure of IDEA create in parents an independent stake not only in the procedures and costs implicated by the process but also in the substantive decision to be made. Incongruous results would follow, moreover, were the Court to accept the proposition that parents’ IDEA rights are limited to certain nonsubstantive matters. It is difficult to disentangle the Act’s procedural and reimbursement-related rights from its substantive ones, and attempting to do so would impose upon parties a confusing and onerous legal regime, one worsened by the absence of any express guidance in IDEA concerning how a court might differentiate between these matters. This bifurcated regime would also leave some parents without any legal remedy. Pp. 9–16.
(c) Respondent misplaces its reliance on Arlington Central School Dist. Bd. of Ed. v. Murphy, 548 U. S. ___, when it contends that because IDEA was passed pursuant to the Spending Clause, it must provide clear notice before it can be interpreted to provide independent rights to parents. Arlington held that IDEA had not furnished clear notice before requiring States to reimburse experts’ fees to prevailing parties in IDEA actions. However, this case does not invoke Arlington’s rule, for the determination that IDEA gives parents independent, enforceable rights does not impose any substantive condition or obligation on States that they would not otherwise be required by law to observe. The basic measure of monetary recovery is not expanded by recognizing that some rights repose in both the parent and the child. Increased costs borne by States defending against suits brought by nonlawyers do not suffice to invoke Spending Clause concerns, particularly in light of provisions in IDEA that empower courts to award attorney’s fees to prevailing educational agencies if a parent files an action for an “improper purpose,” §1415(i)(3)(B)(i)(III). Pp. 16–17.
2. The Sixth Circuit erred in dismissing the Winkelmans’ appeal for lack of counsel. Because parents enjoy rights under IDEA, they are entitled to prosecute IDEA claims on their own behalf. In light of this holding, the Court need not reach petitioners’ argument concerning whether IDEA entitles parents to litigate their child’s claims pro se. Pp. 17–18.
Reversed and remanded.
Kennedy, J., delivered the opinion of the Court, in which Roberts, C. J., and Stevens, Souter, Ginsburg, Breyer, and Alito, JJ., joined. Scalia, J., filed an opinion concurring in the judgment in part and dissenting in part, in which Thomas, J., joined.