Endrew F. v. Douglas Cnty. Sch. Dist. RE-1
137 S. Ct. 988, 85 U.S.L.W. 4109, 197 L. Ed. 2d 335 (2017)
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Rule of Law:
Under the Individuals with Disabilities Education Act (IDEA), a school district must offer a child an Individualized Education Program (IEP) that is reasonably calculated to enable the child to make progress that is appropriate in light of the child's circumstances.
Facts:
- Endrew F., a child diagnosed with autism, attended school in the Douglas County School District from preschool through fourth grade.
- By fourth grade, Endrew's parents became dissatisfied with his academic and functional progress, which they believed had stalled.
- Endrew exhibited significant behavioral issues that inhibited his learning, such as screaming, climbing over furniture, and running away from school.
- His annual Individualized Education Programs (IEPs) largely carried over the same basic goals and objectives from year to year, indicating a lack of meaningful progress.
- In April 2010, the school district proposed a fifth-grade IEP that his parents found to be substantially the same as his previous, ineffective ones.
- His parents unilaterally withdrew him from public school and enrolled him at Firefly Autism House, a private school specializing in educating children with autism.
- At Firefly, a new behavioral intervention plan was implemented, and Endrew's behavior and academic progress improved significantly within months.
- In November 2010, the school district presented a revised IEP, which the parents again rejected as inadequate.
Procedural Posture:
- Endrew F.'s parents filed a complaint with the Colorado Department of Education seeking reimbursement for private school tuition.
- An Administrative Law Judge (ALJ) denied their request, finding the school district had provided a FAPE.
- Endrew's parents sought review in the U.S. District Court for the District of Colorado.
- The District Court affirmed the ALJ's decision, holding that the school district's IEP was sufficient because it aimed for 'minimal progress.'
- Endrew's parents, as appellants, appealed to the U.S. Court of Appeals for the Tenth Circuit.
- The Tenth Circuit affirmed the district court's judgment, holding that an IEP is adequate under the IDEA as long as it is calculated to confer an 'educational benefit [that is] merely ... more than de minimis,' a standard the school district, as appellee, had met.
- The U.S. Supreme Court granted certiorari.
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Issue:
Does the Individuals with Disabilities Education Act (IDEA) require a school to provide an educational program that offers a benefit that is merely more than de minimis to a child with a disability?
Opinions:
Majority - Chief Justice Roberts
No. 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, not merely provide an educational benefit that is more than de minimis. The Court rejected the Tenth Circuit's 'merely more than de minimis' standard as insufficient, finding that it would be tantamount to a child 'sitting idly' and would defeat the core purpose of the IDEA. The Court re-examined its precedent in Board of Ed. v. Rowley, clarifying that while Rowley rejected an 'equal opportunity' standard, it implicitly requires a substantively adequate program focused on progress. An IEP must be 'appropriately ambitious' in light of the child's unique circumstances. For a child fully integrated into a regular classroom, this typically means an IEP designed to achieve passing marks and advancement from grade to grade; for a child not in that situation, the educational program must still be challenging and aim for progress. The Court vacated the lower court's judgment, holding that the IDEA demands more than a trivial educational benefit.
Analysis:
This unanimous decision resolves a circuit split and significantly clarifies the substantive standard for a 'free appropriate public education' (FAPE) under the IDEA. By rejecting the low 'merely more than de minimis' standard used by some courts, the ruling raises the bar for school districts nationwide. It establishes a more robust, individualized standard that focuses on meaningful progress tailored to the child's specific circumstances. This holding empowers parents to challenge inadequate IEPs and requires schools to provide a more cogent justification for their educational plans, ensuring they are 'appropriately ambitious' rather than merely procedural.
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