Endrew F. v. Douglas County School Dist. RE

Endrew F., a child with autism in Colorado, attended Douglas County School District with annual IEPs through fourth grade; his parents believed his progress had stalled under largely unchanged IEPs.
Parents enrolled Endrew in a private specialized school (Firefly) and observed substantial behavioral and academic improvement after implementation of a behavioral intervention plan.
Parents sought reimbursement from the school district under IDEA, arguing the district had failed to provide a timely FAPE before the private placement; administrative and district courts denied relief.
The Tenth Circuit upheld the denial, applying a "more than de minimis" standard for educational benefit from an IEP and finding Endrew made some progress.
The Supreme Court granted certiorari to decide the proper substantive standard for whether an IEP provides a FAPE and vacated and remanded the Tenth Circuit decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper substantive standard for adequacy of an IEP under IDEA	IEP must provide opportunities substantially equal to non-disabled peers; must aim for meaningful academic success and self-sufficiency	Rowley allows any benefit above none; an IEP need only be reasonably calculated to provide some benefit (interpreted by Tenth Cir. as “more than de minimis”)	An IEP must be reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances — more demanding than "more than de minimis" but not an "equal opportunity" rule
Application of Rowley to children not fully integrated/at grade level	Rowley’s guidance should require ambitious goals tailored to the child; progress measured relative to child’s potential	Rowley permits minimal progress for children not on grade level	Rowley supports a child-specific standard: when grade-level advancement is unrealistic, the IEP must still be appropriately ambitious given the child’s circumstances
Role of courts vs. school expertise in reviewing IEPs	Courts should ensure substantive adequacy and meaningful progress	Courts must defer to school authorities’ prospective judgments and expertise	Courts must defer to school expertise but may require a cogent, responsive explanation showing the IEP was reasonably calculated to enable appropriate progress

Board of Ed. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (1982) (established that an IEP must be reasonably calculated to enable a child to receive educational benefits; guidance on grade‑level advancement for children in regular classroom)
Honig v. Doe, 484 U.S. 305 (1988) (described the IEP as the centerpiece of IDEA’s education delivery system and emphasized individualized planning)