This commentary is in response to Tim Keller's article "The National Implications of 'Cain v. Horne.'" In his analysis, Keller asserts that the Arizona Supreme Court wrongfully struck down a voucher program for students with special needs by characterizing the voucher as aid to schools rather than aid to students. In this response to Keller, I discuss why his assessment is incorrect. I also address the broader issue of a child's rights according to the Individuals with Disabilities Act and how those rights are essentially lost when parents choose a private school for their children, a result states should not facilitate with public money in the form of a voucher. (Contains 1 note.)