concurring in part and dissenting in part.
I concur in the court’s judgment to the extent that it affirms the dismissal of the plaintiffs’ claims, but dissent from the conclusion that the plaintiffs’ contact with the school district in 1994 gave rise to a new cause of action under the IDEA. I would affirm the judgment of the district court and briefly write to explain my view of the matter.
The remedies available under 20 U.S.C. § 1415(e)(2)1 may include reimbursement to parents for private school tuition and expenses. See School Comm. v. Department of Educ., 471 U.S. 359, 371, 105 S.Ct. 1996, 85 L.Ed.2d 385 (1985). Disputes about who will be financially responsible for private schooling paid for by the parents is a matter subject to the due process procedures. See id. (citing 34 C.F.R. § 300.403(b)). We have held that parents who are dissatisfied with the publicly funded education being provided to their child must complain and, if necessary, seek a due process hearing before unilaterally withdrawing their child from a public school. See Wise v. Ohio Dept. of Educ., 80 F.3d 177, 184 (6th Cir.1996). I agree that the plaintiffs’ failure to request a due process hearing until six and a half years after withdrawing their child from the district cannot be excused on the grounds that the district failed to provide them adequate notice of their rights.
Although the opinion does not say so, some readers may interpret it to hold that unilateral withdrawal is a complete bar to claims for reimbursement unless a new cause of action arises. I would clarify that unilateral withdrawal is separate from the statute of limitations issue. While this distinction is immaterial here because a due process hearing was not requested within the statute of limitations, this court has not yet decided if, or when, a unilateral withdrawal bars a claim for reimbursement after a request for review has been made.2 Notably, the Court in Burlington rejected the contention that a parental violation of the stay-put provision constitutes a waiver of reimbursement. See 471 U.S. at 372, 105 S.Ct. 1996.
*771The appropriate statute of limitations for claims under the IDEA must be determined on a case-by-case basis. See Janzen v. Knox County Bd. of Educ., 790 F.2d 484, 486-87 (6th Cir.1986). Claims under the IDEA generally accrue when the parents know, or have reason to know, of the injury or event that was the basis of their claim. See Hall v. Knott County Bd. of Educ., 941 F.2d 402 (6th Cir.1991). I agree that plaintiffs’ IDEA claims accrued in 1989 when they unilaterally withdrew their child from the school district. At that time, plaintiffs knew the school was not providing the services they felt their son needed and alleged that he was suffering terribly as a result. As such, plaintiffs’ claims were barred under either the two-year limitations period for personal injury actions, or the four-year limitations period for actions seeking recovery of personal property. See Ohio Rev.Code §§ 2305.09-.10.
I dissent from the majority’s finding that a new cause of action arose in 1994, which was within either limitations period, when the plaintiffs’ inquiries about returning to the district were rebuffed for a second time. Despite having acknowledged that there is no clear law on the issue, the opinion nonetheless expressly holds, without analysis, that “refusing to do an IEP pre-enrollment constitutes [ ] a violation [of the IDEA].” (Para.14).3 Without resolving this question, particularly given the dearth of authority provided on the issue, I would conclude that the plaintiffs’ 1994 contact with the district did not constitute a new cause of action as it did not involve the refusal to prepare a pre-enrollment IEP.
Factually, plaintiffs’ claims concerning the 1990 and 1994 contacts with the school must be distinguished. In March 1990, the district agreed to re-evaluate plaintiffs’ son and to meet with them to discuss the results. The district, however, would not review or prepare an IEP unless he was re-enrolled in the district. When plaintiffs expressed an intention to re-enroll him, the district agreed to participate in an IEP meeting with the private school. The district nonetheless continued to refuse to review the IEP and recommend changes until he was re-enrolled. Plaintiffs kept their son in the private school. Without deciding whether a new cause of action was triggered by these events, I would find that such a claim would have accrued in 1990 and would be outside either statute of limitations period.
With respect to the 1994 contact, however, plaintiffs allege that they met with the district’s director of special education after the end of the school year to discuss their child’s possible return to the district. They were told not to bring him back then, but to give her “a couple of years to get someone trained.” Certainly, plaintiffs were rebuffed and discouraged from returning their son to the district. At the same time, however, plaintiffs did not request an evaluation, seek a private placement, or again request that an IEP be prepared. Even if a refusal to prepare a pre-enrollment IEP could constitute a violation of the IDEA, plaintiffs’ 1994 contact falls short. I would find that no new cause of action accrued in 1994 and, accordingly, that all of plaintiffs’ IDEA claims were barred by the statute of limitations.
. Although significant amendments to the IDEA were enacted in 1997, the parties agreed that the amended provisions do not apply in this case. See Pub.L. No. 105-17, Title II, § 201(a)(2)(C) (June 4, 1997). The statutory sections cited in this case, therefore, are the pre-amendment provisions.
. In fact, the Third Circuit has held that “when parents unilaterally withdraw their children from public school, absent mitigating circumstances, they are not entitled to reimbursement for private school tuition until they request review proceedings.” Warren G. v. Cumberland County Sch. Dist., 190 F.3d 80, 84 (3d Cir.1999) (citing Bernardsville Bd. of Educ. v. J.H., 42 F.3d 149, 156-58 & n. 14 (3d Cir.1994)).
. The only case cited in support of this holding did not involve this issue, but noted in its recitation of the facts that the school district realized it had an obligation to prepare an IEP before the child re-enrolled. See Cleveland Heights-University Heights Sch. Hist. v. Boss, 144 F.3d 391, 394 (6th Cir.1998).