Victory for Parents: PA Court Upholds Right to Due Process Over Student Records
A recent decision from the U.S. District Court for the Eastern District of Pennsylvania has delivered a significant win for parents of students with disabilities, clarifying their right to challenge a denial of access to educational records through the due process system.
Posted on October 21, 2025, the ruling in Sandra S. v. Upper Darby Sch. Dist. confirms that parents can initiate a due process complaint under the Individuals with Disabilities Education Act (IDEA) solely based on a school district's refusal to provide all requested educational records.
The Core of the Dispute
The case involved parents of a student with autism who, through their attorney, requested their child's educational records from the District. When the District failed to produce all the records, the parents filed a due process complaint.
The District attempted to dismiss the remaining claim after an independent education evaluation mooted the initial complaint, arguing that the IDEA's due process mechanism could not be used just to challenge a records denial. However, the federal court disagreed.
The Court's Key Finding on IDEA
The Court's conclusion centered on the broad scope of the IDEA, which grants parents the right to review all records relating to their child. The IDEA permits parents to file a due process complaint concerning "any matter relating to the identification, evaluation, or educational placement of the child, or the provision of a free appropriate public education".
The Court held that the phrase "Any matter" includes the fundamental right to access educational records. This access is crucial because it ensures parents can fully participate in discussions about their child’s needs and determine whether the student is receiving a Free Appropriate Public Education (FAPE).
What This Means for Families and Schools
This decision emphasizes a critical procedural right for parents across Pennsylvania and serves as a powerful reminder to school districts:
* Empowered Parents: Parents can now directly challenge the denial of educational records using the established IDEA due process procedures, rather than relying on other, less direct legal avenues.
* Procedural Compliance: School districts are on notice that they must be highly vigilant in complying with the legal rights of parents and guardians to access their student's records under the IDEA.
While parents still bear the ultimate burden of establishing a denial of FAPE, this ruling makes it easier to obtain the foundational evidence, the records, needed to pursue that goal. It reaffirms the parent's role as a co-equal partner in their child's special education journey.
