Students with Prader-Willi Syndrome: Judicial Case Law under the IDEA

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Zirkel 2025
Published: Dec 30, 2025
DOI: https://doi.org/10.14434/rapcc.v43i3.42104
Keywords:
Case Law, IDEA, Prader-Willi Syndrome (PWS)

Main Article Content

Perry A. Zirkel

Abstract

Prader–Willi syndrome (PWS) is a low-incidence genetic disability that has received correspondingly limited attention in Individuals with Disabilities Education Act (IDEA) case law. An earlier review identified only three court decisions addressing IDEA claims for students with PWS and cautioned against generalization due to limited data and varied factual contexts. This article provides an eight-year update of IDEA case law specific to students with PWS, with primary emphasis on judicial decisions, given their precedential weight relative to due process hearing and state complaint outcomes.

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How to Cite
Zirkel, P. (2025). Students with Prader-Willi Syndrome: Judicial Case Law under the IDEA. Research, Advocacy, and Practice for Complex and Chronic Conditions, 43(3), 5–11. https://doi.org/10.14434/rapcc.v43i3.42104
Issue
Vol. 43 No. 3 (2025): Research, Advocacy, and Practice: for complex and chronic conditions, A Journal for Physical, Health, and Multiple Disabilities
Section
Advocacy and Policy

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Author Biography

Perry A. Zirkel

Perry A. Zirkel
University Professor Emeritus of Education & Law
Lehigh University website: perryzirkel.com

References

Aileen v. Department of Education, State of Hawaii, 56 IDELR ¶ 297 (D. Haw. 2011).

Central Bucks School District v. Q.M., 81 IDELR ¶ 258 (E.D. Pa. 2022a).

Central Bucks School District v. Q.M., 82 IDELR ¶ 56 (E.D. Pa. 2022b).

Donovan v. Norwich School District, 80 IDELR ¶ 188 (N.D.N.Y. 2022).

Endrew F. v. Douglas County School District RE-1, 580 U.S. 386, 399 (2017).

Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §§ 1400 et seq.

K.C. v. Nazareth School District, 806 F. Supp. 3d 806 (E.D. Pa. 2011).

K.D. v. Los Angeles Unified School District, 816 F. App’x 222 (9th Cir. 2020), further proceedings, 2021 WL 3468110 (9th Cir. Mar. 5, 2021).

Lincoln County School District, 124 LRP 41517 (Or. SEA 2024).

Q.M. v. Central Bucks School District, 2024 WL 84177 (E.D. Pa. Feb. 28, 2024).

S.C. v. Lincoln County School District, 16 F.4th 587 (9th Cir. 2021).

S.C. v. Lincoln County School District, 2022 WL (D. Or. June 18, 2022).

Schiff v. District of Columbia, 75 IDELR ¶ 256 (D.D.C. 2019).

Schiff v. District of Columbia, 2025 WL 4059469 (D.D.C. Sept. 7, 2021).

S.H. v. Rutherford County Schools, 334 F. Supp. 3d 868 (M.D. Tenn. 2018).

Tinton Falls Board of Education, 2018 LRP 15799 (N.J. SEA 2018).

Yell, M.L. (2025). The law and special education (6th ed.). Pearson.

Zachary G. v. School District No. 1, 68 IDELR ¶ 222 (D. Colo. 2016).

Zirkel, P. A. (2015). Special education law: Illustrative basics and nuances of key IDEA components. Teacher Education and Special Education, 38, 263–275. https://doi.org/10.1177/0888406415575377

Zirkel, P. A. (2017). Students with Prader-Willi Syndrome: Case law under the IDEA. Physical Disabilities: Education and Related Services, 36, 35–44. https://doi.org/10.14434/pders.v36i2.24267

Zirkel, P. A. (2019). A comparison of the IDEA’s dispute resolution processes—State complaint procedures and due process hearings. West’s Education Law Reporter, 369, 550–563.

Zirkel, P. A. (2022). Stay-Put under the IDEA: The latest overview. West’s Education Law Reporter, 404, 398–414.

Zirkel, P. A., & Holben, D. M. (2025). Due process hearing decisions under the IDEA: A follow-up outcomes analysis with and without New York. West’s Education Law Reporter, 431, 394–401.

Zirkel, P. A., & Karanxha, Z. (2024). Longitudinal trends in special education case law: An updated analysis. Journal of Special Education Leadership, 37(1), 42–51.