Advisory on Endrew F. v. Douglas County School District RE-1, 2017 U.S. Supreme Court Decision of Special Education


On March 22, 2017, the U.S. Supreme Court issued its unanimous decision in Endrew F. v. Douglas County School District RE-1, 580 U.S. __, No. 15-827 (Mar. 22, 2017). The decision, written by Chief Justice Roberts, addresses the standard that school districts must meet in providing Individualized Education Programs (IEPs) to students with disabilities under the federal Individuals with Disabilities Education Act (IDEA). The Supreme Court held: "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 rejected the less demanding standard - "merely more than de minimis" educational benefit - that the U.S. Court of Appeals for the Tenth Circuit had applied in this case, which arose in Colorado.