The U.S. Supreme court made a determination that the parents of a disabled child, who was never enrolled in the public school district, were entitled to reimbursement of private school tuition. (Board of Education of City School District of New York v Tom F.)
In addition, a U.S. District court of Illinois ruled that parents of disabled children over the age of 18 do not have independent, enforceable rights under the IDEA, and therefore dismissed an appeal of an administrative hearing decision against an Illinois school district. The opinion can be found at Loch v Board of Education of Edwardsville Community School District 7.