1. May a school district condition its provision of
special education and related services to a disabled
child under the Individuals with Disabilities Educa
tion Act, 20 U.S.C. 1400 et seq. ("IDEA "), on a parent 's
agreement to prospectively waive the child 's federal
statutory rights and civil rights?

2. What steps must a parent take to invoke
procedural safeguards under the IDEA, 20 U.S.C.
1415(f)(l)(B)(iv), to void an educational placement
and settlement agreement (EPSA), within three days
of execution?

3. When an EPSA between a school district and
parent (on behalf of a disabled child) states it is gov
erned by state law, is a federal court bound to follow
State Supreme Court precedent in deciding whether
exculpatory provisions in the EPSA waiving the child 's
prospective rights including state statutory and com
mon law rights, are enforceable?

Whether a school district can condition special education services on a parent's agreement to waive a child's federal statutory and civil rights