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Endrew F. v. Douglas County School District

Supreme Court of the United States · 2017 · Constitutional Law

Constitutional LawIndividuals with Disabilities Education ActFree Appropriate Public EducationIndividualized Education ProgramIDEAFAPEIEPspecial education

Facts

Endrew F., a child with autism, attended schools in the Douglas County School District from preschool through fourth grade and received annual IEPs. By fourth grade, his parents believed his academic and functional progress had stalled and objected when the district proposed a fifth-grade IEP they viewed as essentially the same as prior plans. They removed him from public school and enrolled him in a private school specializing in autism, where he improved significantly after receiving a behavioral intervention plan and stronger academic goals. When the district later proposed another IEP that Endrew's parents still considered inadequate, they sought tuition reimbursement on the ground that the district had failed to provide a FAPE.

Issue

What substantive standard governs whether an IEP provides a free appropriate public education under the IDEA? Specifically, is an IEP sufficient if it is reasonably calculated to confer merely more than de minimis educational benefit, or must it be reasonably calculated to enable progress appropriate in light of the child's circumstances?

Rule

To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances. For a child fully integrated in the regular classroom, an IEP typically should be reasonably calculated to enable the child to achieve passing marks and advance from grade to grade; for a child not fully integrated in the regular classroom or not able to achieve on grade level, the educational program must still be appropriately ambitious in light of that child's circumstances and give the child the chance to meet challenging objectives.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, Maya Ortiz is a seventh grader with a learning disability who spends the full school day in general education classes with supports. Her IEP provides accommodations and targeted instruction designed to help her earn passing grades in her classes and move to eighth grade, and the plan is based on her current performance data. Her father argues the district violated the IDEA because the plan does not maximize her achievement or guarantee she will perform as well as students without disabilities.

Which is the best assessment of the IEP's substantive adequacy under the governing standard?

Explanation. For a child fully integrated in the regular classroom, an IEP typically should be reasonably calculated to enable the child to achieve passing marks and advance from grade to grade. The governing inquiry is whether the IEP is reasonable, not ideal, and the Court rejected a rule requiring substantially equal educational opportunity or any guarantee of a particular outcome. (Derived from Endrew F. v. Douglas County School District (n.d.).)