Two cases, Mills v. Board of Education of District of Columbia (1972) and Pennsylvania Association for Retarded Children v. Commonwealth of Pennsylvania (PARC, 1971, 1972), were major elements in helping to lay the foundation for the 1975 enactment of the Education for All Handicapped Children Act, now known as the Individuals with Disabilities Education Act (IDEA). Prior to that time, millions of students with disabilities were either excluded from public education totally or were admitted but did not receive appropriate services. While only heard at the federal trial court level, the decisions in Mills and PARC are truly landmark cases in the evolution of federal special education law.