U.S. Supreme Court Makes Landmark Ruling on Educational Benefit for Individuals with Disabilities

Parents of children with disabilities received some good news recently. The U.S. Supreme Court ruled in favor of a Colorado family with a child with autism and attention deficit/hyperactivity disorder regarding the educational benefit that schools must provide to children with disabilities.

The decision comes a few weeks before the start of Autism Awareness Month in April, but this case will impact many children with various disabilities, not only autism. The case revolved around a boy, Endrew, whose parents took him out of school before fifth grade because they felt he was not progressing under the individualized education plan (IEP) developed by his school district. The parents enrolled him in a private school specializing in educating children with autism and Endrew made better progress.

Endrew’s parents then sued the school district for reimbursement of the private school tuition. They said that the school district did not provide Endrew with a “free appropriate public education” as defined under the Individuals with Disabilities Education Act (IDEA.) The school district denied the request. At issue was the level of educational benefit that IDEA requires school districts to provide to children. In other words, what does “free appropriate public education” mean? Endrew’s parents argued that the school district should provide a “substantial” education, not just a “minimal” education.

About 6.5 million IEP’s are written each year across the country. Because the standard is not clear, school districts in different states offer different educational programs to students. Endrew’s family appealed the school district’s decision in court and the case, Endrew F. v. Douglas County School District, went up to the U.S. Court of Appeals for the Tenth Circuit, the last level before the U.S. Supreme Court.

The Tenth Circuit said that Endrew’s IEP was adequate and that a ‘de minimus’ educational benefit was all a school district needed to provide. The Tenth Circuit held that Endrew’s IEP had been “reasonably calculated” to enable him to make “some progress” and the parents’ claim was denied. The U.S. Supreme Court heard the case last month and overturned the lower court’s decision, ruling for the family.  The high court felt that IDEA required more than just “some” progress, saying “this standard is markedly more demanding than the “merely more than de minimus” test applied by the Tenth Circuit.” “It requires an educational program reasonably calculated to enable a child to make progress in light of the child’s circumstances,” Chief Justice John Roberts wrote for the court.

The Supreme Court also noted, however, that the standard does not require equal progress among students with disabilities and their typical peers. “A child’s IEP need not aim for grade-level advancement if that is not a reasonable prospect. But that child’s educational program must be appropriately ambitious in light of his circumstances, just as advancement from grade to grade is appropriately ambitious for most children in the regular classroom. The goals may differ, but every child should have the chance to meet challenging objectives,” the court wrote. The court did not clearly define what an “appropriate” education under IDEA really means, as many people had expected. “We will not attempt to elaborate on what “appropriate” progress will look like from case to case,” Roberts wrote.

What The Supreme Court Ruling Means for Massachusetts
Massachusetts, known for having one of the best school systems in the country, is progressive in its approach to developing IEPs for children. Massachusetts law requires that a student’s IEP “be tailored to address the student’s unique needs” so that a student can make “meaningful and effective educational progress.” Public schools in Massachusetts must also offer eligible students a special education program and services specifically designed for each student in order to develop the student’s “educational potential.” The ruling was made in a Special Education Appeals case, Student v. Salem Public Schools in 2010.

Local school officials say that Massachusetts is already applying a higher standard under IDEA. “I think we are already doing it in Massachusetts because we have a higher standard. We always provide the maximum feasible benefit. I think it’s holding other states accountable,” said Susan Doe, Seekonk Administrator of Special Services.

To read the Supreme Court’s decision in Endrew, go to https://www.supremecourt.gov/opinions/16pdf/15-827_0pm1.pdf or search: “Supreme Court opinion in Endrew F. v. Douglas County School District.”