Endrew F. v. Douglas County School District - Post-Decision SCOTUScast
SCOTUScast featuring Daniel Woodring
SCOTUScast featuring Daniel Woodring
On March 22, 2017, the Supreme Court decided Endrew F. v. Douglas County School District, a dispute involving the Individuals with Disabilities Education Act (IDEA), which in exchange for federal funding requires that states provide a “free appropriate public education” (FAPE) to disabled children by means of a tailored “individualized education program” (IEP). In its 1982 decision Board of Ed. of Hendrick Hudson Central School Dist., Westchester County. v. Rowley (Rowley), the Supreme Court indicated that the FAPE requirement is satisfied when an IEP is “reasonably calculated to enable the [disabled] child to receive educational benefits.”
Endrew F. is a student with autism who received annual IEPs from the Douglas County School District from preschool through the fourth grade. At that point, however, his parents felt his progress to be stagnating, and when the school district proposed a similar IEP for the fifth grade, Endrew’s parents moved him to a specialized private school where he made significant progress. School district officials thereafter presented Endrew’s parents with a revised IEP, but the parents considered it little better than the previous version. The parents sought reimbursement of private school tuition costs by filing an IDEA complaint with the Colorado Department of Education. Their claim was denied, however, and the denial was affirmed by both a federal district court and the U.S. Court of Appeals for the Tenth Circuit. The Tenth Circuit concluded that under Rowley, the FAPE requirement was satisfied so long as the IEP conferred more than a minimal educational benefit.
By a vote of 8-0, the Supreme Court vacated the judgment of the Tenth Circuit and remanded the case. Writing for a unanimous Court, Chief Justice Roberts indicated that 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,” a more demanding standard than the Tenth Circuit’s de minimis one. The Court then remanded the case for further proceedings under the corrected standard.
To discuss the case, we have Daniel Woodring, principal at Woodring Law Firm.
Principal Attorney, Woodring Law Firm
Mr. Daniel Woodring has lived in Florida for almost 30 years, but was born in Philadelphia, Pennsylvania. In Florida, he has lived and worked in Pensacola, Clearwater, Jacksonville, Gainesville and Tallahassee. His wife Jean, who is also an attorney, was born in Miami, and grew up in Ft. Myers. They have a son and a daughter.
Mr. Woodring is recognized as a Florida Super Lawyer, an honor given to fewer than 5% of Florida Attorneys, and holds an Avvo “Superb” rating. Mr. Woodring also has an AV Preeminent® Peer Reviewrating. AV®, AV Preeminent® are registered certification marks of Reed Elsevier Properties Inc., used in accordance with the Martindale-Hubbell certification procedures, standards and policies, and the ratings are explained at www.martindale.com/ratings.
Mr. Woodring is a member of the Florida and Georgia Bars, and is admitted to practice before the Florida Federal Southern, Middle and Northern District Courts, the Eleventh Circuit Court of Appeals and the U.S. Supreme Court. He has worked at the trial level on cases in many of Florida’s 20 judicial circuits, in addition to cases in state administrative tribunals. He has argued cases at the Florida Supreme Court and Florida District Courts of Appeal, and has briefed cases at the U.S. Supreme Court.
He graduated from the University of Florida, College of Law with a Juris Doctorate, Cum Laude, and received his B.A. degree from Clearwater Christian College, Summa Cum Laude.
After law school, Mr. Woodring was in private practice doing general civil and appellate work. He then left for a two year appellate clerkship at the First District Court of Appeal. During his time at the court, he worked on cases including, but not limited to: criminal; family law; administrative law; workers’ compensation; business and civil law; constitutional law.
Mr. Woodring next worked as a counsel in the Executive Office of the Governor, Office of the General Counsel. During his time in Governor Bush’s Legal Office he had diverse responsibilities, including oversight and strategic litigation management of significant legal matters at numerous Governor’s agencies, including the Department of Education, Department of Management Services, Department of Business and Professional Regulation, Department of Health, Agency for Health Care Administration, Department of Children and Families, Department of Community Affairs, Department of Elder affairs, Agency for Workforce Innovation, Department of Transportation, and the Department of State.
He was also legally responsible for topics as disparate as emergency operations; advising the Governor on the selection of judges; implementation of civil service reform; reform of workers’ compensation; budget and appropriation matters; Indian gaming law; and legally advising the Florida Cabinet sitting in its many capacities, such as the Florida Land and Water Adjudicatory Commission.
Mr. Daniel Woodring was then offered the opportunity to be General Counsel for the Florida Department of Education, which encompassed Pre-K though 12th grade, community colleges(now State colleges) and the Florida University System. He was also the first General Counsel for the Florida Board of Governors, when that Board was constitutionally created to manage the State University System.
During almost five years at the Department of Education, Mr. Woodring advised and litigated on matters including, but not limited to: constitutional challenges to Florida’s education programs, including Opportunity Scholarships and the charter school approval and appeal process; doing away with race as a preference in university admissions and state contracting; teacher and professional discipline cases; union, labor and employment matters; state procurement and bid protest proceedings; administrative rule challenges and rule making proceedings; IDEA and Section 504 proceedings; public records, government in the sunshine and ethical matters; contract negotiations and disputes.
Since 2007, Mr. Woodring has been back in private practice as the principal of the Woodring Law Firm, located in Tallahassee, Florida, but with a statewide practice, including Pensacola, Jacksonville, Gainesville, Tampa Bay, Orlando, West Palm Beach, Ft. Myers, Ft. Lauderdale, and Miami. He concentrates his practice on appeals; constitutional cases in both state and federal court; education law matters, including charter school represention; Business litigation; and state administrative matters, including state procurement, regulation and licensing, rule challenges and proposed rule making, although he also handles cases in many other areas.
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Mr. Woodring is a member of the Appellate, Administrative, and Governmental Lawyer sections of the Florida Bar and served as Chair of the Education Law Committee of the Florida Bar.