Endrew F. v. Douglas County School District Re-1

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Civil Law
  • Date Filed: March 22, 2017
  • Case #: 15-827
  • Judge(s)/Court Below: Roberts, C.J., delivered the opinion for a unanimous Court
  • Full Text Opinion

For a school to meet its substantive obligation under the Individuals with Disabilities Education Act, it must offer an Individualized Education Program that is "reasonably calculated to enable a child [with a qualifying disability] to make progress appropriate in light of the child's circumstances."

Petitioner was diagnosed with autism at age two and qualified as a child with a disability under the Individuals with Disabilities Education Act (IDEA). Petitioner had an Individualized Education Program (IEP) in place through fourth grade, but in the fourth grade his parents became unhappy with his progress. The Douglas County School District (Respondent) presented essentially the same IEP for Petitioner's fifth grade year so his parents removed him from public school and placed him in a private school that specialized in educating children with autism, where Petitioner improved significantly. Six months after Petitioner began at the private school his parents again met with the Respondent who presented a similar IEP, which the parents considered inadequate, therefore they filed a complaint with the Colorado Department of Education seeking reimbursement for Petitioner's tuition at the private school. An Administrative Law Judge denied relief, holding that the IEP was reasonably calculated to allow Petitioner to obtain educational benefits. A Federal District Court and the Court of Appeals for the 10th Circuit affirmed. The Supreme Court held that for a school to meet its substantive obligation under the IDEA, it must offer an IEP “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” The instruction offered to the child must be specially designed to meet that child’s unique needs through a personalized program. The Supreme Court declined to create a bright line test, holding that what constitutes “appropriate” progress varies from case to case and the sufficiency of an IEP depends on the unique circumstances of the child for whom it is made. The statement in Board of Ed. Of Hendrick Hudson Central School Dist., Westchester City v. Rowley, 458 U.S. 176, that the IDEA did not promise any specific level of education reflects the proposition that IDEA cannot and does not promise any specific educational outcome, as no law could do that for any child. VACATED and REMANDED.

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