Law School Case Brief
Endrew F. v. Douglas Cty. Sch. Dist. RE-1 - 137 S. Ct. 988 (2017)
The Individuals with Disabilities Education Act, 20 U.S.C.S. § 1400 et seq., establishes a substantive right to a “free appropriate public education” for certain children with disabilities.
Petitioner Endrew, a child with autism, received annual Individualized Education Program (IEP) evaluations in respondent Douglas County School District from preschool through fourth grade. By fourth grade, Endrew's parents believed his academic and functional progress had stalled. When the school district proposed a fifth grade IEP that resembled those from past years, Endrew's parents removed him from public school and enrolled him in a specialized private school, where he made significant progress. Petitioner’s parents filed a complaint under the Individual with Disabilities Education Act (IDEA) for reimbursement for the child’s expenses in private school. Their claim was denied by the Colorado Department of Education, which was affirmed by the district court. The Court of Appeals for the Tenth Circuit also affirmed. Petitioner Endrew and his parents sought certiorari review.
Did the defendant county school deprive petitioner of his right to free appropriate public education (FAPE) under the Individual with Disabilities Education Act (IDEA)?
The United States Supreme Court held that the nature of the IEP process ensures that parents and school representatives will fully air their respective opinions on the degree of progress a child's IEP should pursue; thus, by the time any dispute reaches court, school authorities will have had the chance to bring their expertise and judgment to bear on areas of disagreement. When a child is fully integrated in the regular classroom, providing a FAPE that meets the unique needs of a child with a disability typically means providing a level of instruction reasonably calculated to permit advancement through the general curriculum. Concluding that a school district, in order 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, the court vacated the judgment of the court and remanded for further proceedings.
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