Endrew F. v. Douglas Cnty. Sch. Dist. RE-1
580 U.S. 386
SCOTUS2017Background
- The Individuals with Disabilities Education Act (IDEA) requires states receiving federal funds to provide a free appropriate public education (FAPE) through an individualized education program (IEP).
- Rowley established that IDEA guarantees a substantive right to a FAPE and that an IEP must be “reasonably calculated to enable the child to receive educational benefits,” but declined to articulate a single test for adequacy.
- Endrew F., a child with autism, attended Douglas County (Colo.) public schools through fourth grade; his parents removed him to a private autism-specialized school (Firefly) after concluding the district’s IEPs produced minimal progress.
- At Firefly, Endrew made substantial behavioral and academic gains under a behavioral intervention plan and more ambitious goals.
- The parents sought tuition reimbursement from the district, arguing the district had denied Endrew a FAPE; administrative and lower federal courts (applying a “more than de minimis” standard) denied relief, and the Tenth Circuit affirmed.
- The Supreme Court granted certiorari to decide the appropriate substantive standard for determining whether an IEP provides a FAPE.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper substantive standard for FAPE under IDEA | FAPE must offer opportunities substantially equal to nondisabled peers — enable academic success, self-sufficiency, contribution to society | Rowley means any IEP reasonably calculated to confer "some" educational benefit (i.e., more than de minimis) satisfies IDEA | An IEP must be reasonably calculated to enable progress appropriate in light of the child’s circumstances — more demanding than a mere de minimis standard |
| Application to Endrew’s case (sufficiency of district IEP) | District IEPs failed to address Endrew’s behavioral needs and were not appropriately ambitious given his circumstances; parents sought reimbursement for private placement | District contended its IEPs were reasonable and provided some educational benefit; lower courts deferred to ALJ and applied a minimal-progress standard | Vacated Tenth Circuit; remanded for application of the appropriate standard (IEP must show an explanation that it is reasonably calculated to enable appropriate progress) |
Key Cases Cited
- Board of Ed. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (1982) (establishes IDEA’s substantive FAPE requirement: IEP must be reasonably calculated to confer educational benefit; declined to adopt single test)
- Honig v. Doe, 484 U.S. 305 (1988) (describes the IEP as the centerpiece of IDEA’s education-delivery system)
- Arlington Cent. Sch. Dist. Bd. of Ed. v. Murphy, 548 U.S. 291 (2006) (discusses IDEA funding structure and statutory framework)