Endrew F. v. Douglas County School District

Facts of the Case

Provided by Oyez

Endrew F. is an autistic fifth grade student who was placed in private school because his parents believed his public school education was inadequate. Endrew was placed in Firefly Autism House and his parents sued for reimbursement of Endrew’s private school tuition and related expenses pursuant to the Individuals with Disabilities Act (IDEA). IDEA provides that if a free public school cannot meet the educational needs of a disabled student, the student’s parents may enroll their child in a private school and seek reimbursement for tuition and related expenses.

This case first went to an Administrative Law Judge (ALJ) for review. The ALJ rejected Endrew’s parent’s request for reimbursement concluding that Endrew’s public school had provided him with “free appropriate public education” (FAPE) as required by the IDEA. The district court affirmed the ALJ’s ruling and held that Endrew’s parents failed to meet their burden to prove that Endrew was not provided with FAPE. The U.S. Court of Appeals for the Tenth Circuit affirmed.

Questions

What is the level of educational benefit that school districts must confer on children with disabilities to provide them with the free appropriate public education guaranteed by the Individuals with Disabilities Education Act (IDEA)?

Conclusions

In order to provide children with disabilities the free appropriate public education guaranteed by under the Individuals with Disabilities Education Act (IDEA), school districts must offer children an Individualized Education Program (IEP) that is reasonably calculated to enable each child to make progress appropriate for that child’s circumstances. Chief Justice John G. Roberts, Jr., delivered the opinion for the unanimous Court, which held that the inquiry into whether an IEP is reasonably calculated to allow a child to make progress is necessarily an intensive, fact-specific one and therefore neither the Court nor the statute could create a substantive standard. The Court’s decision in Board of Education of Hendrick Hudson Central School District v. Rowley suggests that “appropriate progress” for most children would allow them to be fully integrated into the classroom and to advance from grade to grade. This requirement is substantially more than the “de minimus” benefit that the school district argued was all it was required to provide. However, the Court also held that the standard Endrew F.’s parents argued for was too rigorous and was similar to one that the Court had rejected in its decision in Rowley. In conducting its fact-intensive inquiry, a reviewing court should give deference to the expertise of school authorities but must still ensure that an IEP is reasonably calculated to enable each child to make progress appropriate for that child’s circumstances.