Sara Brisco v. Gerry Brisco

United States Court of Appeals
For the Eighth Circuit
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No. 25-1792
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Sara Brisco
Plaintiff - Appellant
v.
Gerry Brisco; Meeker And Wright Special Education Cooperative, MAWSECO;
Delano Public Schools System
Defendants - Appellees
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Appeal from United States District Court
for the District of Minnesota
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Submitted: December 12, 2025
Filed: December 17, 2025
[Unpublished]
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Before BENTON, SHEPHERD, and KELLY, Circuit Judges.
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PER CURIAM.
Sara Brisco appeals the district court’s1 dismissal of her pro se complaint
raising claims related to the education received by her children with special needs.
Having jurisdiction under 28 U.S.C. § 1291, this court affirms.
1 The Honorable David S. Doty, United States District Judge for the District
of Minnesota.

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-2-
This court reviews de novo the district court’s dismissal of Brisco’s pro se
complaint. See Cook v. George’s, Inc., 952 F.3d 935, 938 (8th Cir. 2020) (standard
of review). Brisco’s complaint asserts a Title II Americans with Disabilities Act
(ADA) claim on behalf of her children against Gerry Brisco, the Meeker and Wright
Special Education Cooperative, and the Delano Public Schools System. Brisco
cannot maintain a claim against Gerry Brisco as there is no individual liability under
the ADA. See Alsbrook v. City of Maumelle, 184 F.3d 999, 1005 n.8 (8th Cir. 1999)
(“Title II provides disabled individuals redress for discrimination by a ‘public
entity.’ That term, as it is defined within the statute, does not include individuals.”
(quoting 42 U.S.C. § 12132)). Additionally, she cannot maintain her ADA claims
against the special education cooperative and the school system. True, “[p]arents
have standing to sue when practices and policies of a school threaten their rights and
interests and those of their children.” Liddle v. Special Admin. Bd. of Transitional
Sch. Dist. of City of St. Louis, 894 F.3d 959, 965–66 (8th Cir. 2018). But parents
cannot bring such a lawsuit pro se. See Crozier for A.C. v. Westside Cmty. Sch. Dist.,
973 F.3d 882, 887 (8th Cir. 2020) (“Non-attorney parents cannot litigate pro se on
behalf of their minor children, even if the minors cannot then bring the claim
themselves.”). After a careful review of the record and the parties’ arguments on
appeal, this court finds no basis for reversal.
The judgment is affirmed. See 8th Cir. R. 47B.
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