This is the first installment in a series of posts regarding the impact the 2017 United States Supreme Court’s unanimous decision in Endrew F. v. Douglas County School District Re-1 (137 S. Ct. 988) has on public schools.
specialized in serving students with autism because they believed the District had not offered Endrew an appropriate IEP for the 5th grade.
progressed in his strong academic goals.
parents contended was basically the same IEP offered previously.
parents’ complaint was
-the IEP offered by District was unchanged from previous years,
-that Endrew had made minimal progress, and
-he was entitled to an education that was “substantially equal to the opportunities afforded children without disabilities.”
tuition reimbursement, stating that Douglas County SD had offered an IEP that would confer educational benefit. (District prevailed.)
sufficient because it was calculated to result in progress, even if it was minimal. (District prevailed.)
–De minimis educational benefit is an amount that is small enough to be ignored; insignificant;
-“[a] student offered an educational program providing merely more than de minimis progress from year to year can hardly be said to have been offered an education at all…The IDEA demands more.”
-determining whether the IEP of a particular child is “reasonably calculated” for that child to make progress requires an “intensive, fact-specific” inquiry.
-crafting an IEP that is appropriate and “reasonably calculated” for the student to make progress requires “a prospective judgment by school officials, informed by their own expertise and the views of a child’s parents or guardians”
-SCOTUS invoked the Rowley decision to disagree with parents’ claim that FAPE required students with disabilities be provided educational opportunities that are “substantially equal” to their typical peers.