In what circumstances will a court grant a parent's right to sue a city for failing to provide adequate education for their children?

In Pasadena City Bd. of Education v. Spangler (1976) 427 U.S. 424, 96 S.Ct. 2697, 49 L.Ed.2d 599, the court recognized the derivative nature of any parent's right in holding that the action was moot as to the individual respondents, the original student plaintiffs and their parents, because the [91 Cal.App.3d 886] students had all graduated from the school system under attack. (427 U.S. at pp. 429-430, 96 S.Ct. 2697.)