Endrew F Vs. Douglas County School district

Endrew F. Vs Douglas County School District

Endrew F Vs. Douglas County School district

Argued January 11, 2017 decided March 22, 2017

Supreme Court of the United States

Facts of the case:

The courts must determine whether or not Endrew was denied a FAPE (free and appropriate public education) even though it was proved that he made “minimal progress” within the school district.

Allegations of the Plaintiff

• The plaintiff, Endrew F’s parents, felt that the Douglas County school district (defendant) was in violation of FAPE in regards to their son’s IEP. At Endrew’s fifth grade IEP meeting, they pulled him from public school and placed him in private school stating that the proposed goals were not allowing him to make significant progress. When he went to private school, however, they were able to educate him in a way that helped him make significant progress that the school district was not able to provide for him.

• Parents sought reimbursement for private school tuition costs with the Colorado Department of Education. In order to do this, parents had to prove that their child was denied FAPE in the public setting.

Defendant's Claim

Douglas county argued that they provided FAPE through equal opportunity and individualized treatment. They claimed that they provided benefits through the IEP and the child made small progress which was indicated by the IEP.

Orders and implications

Orders:

Little information about the Court’s order to parties is given. However, it was concluded that the school district was not providing at an appropriate education because he was not making significant progress. He was receiving a minimal education and not being “pushed” to make the educational success he was capable of.

Principle of the case (reason for litigation):

Endrew F. was denied a FAPE through the public school system which was proved through lack of progress in the public school setting

Implications:

For district: Katy ISD does an excellent job of demonstrating progress and writing IEP goals that demonstrate significant progress in students served through special education. It will hold the district more accountable for developing programs and IEPs that significantly impact and improve students’ success through intensive interventions and access to services and trainings.

For my role in Katy ISD: In my role as a teacher for Katy ISD, it will require me to write IEP goals that are attainable but challenging so that students can demonstrate significant progress. The standard should not be to just “write goals” that demonstrate minimal progress. Goals, behavior plans, etc. should be written that allow students to make significant progress and IEP paperwork should reflect the goal of making significant progress.

Issues the court must resolve

Final Supreme Court holding and reasoning:

• “To meet its substantive obligation under the Individuals with Disabilities Education Act, a school must offer an "individualized education program" reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances.” Unanimously agreed with the Plaintiff 8-0

• The courts unanimously agreed in favor of Endrew F stating that he was denied a FAPE in the public setting because he was able to show significant progress in a private setting… whereas, the public school was not able to help him make the same progress.

• To help them come to a decision, the courts addressed the following case: Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley

Original holding by district court:

Citations:

Endrew F Vs. Douglas County School district

Argued January 11, 2017 decided March 22, 2017

Supreme Court of the United States

Additional information retrieved from https://www.theatlantic.com/education/archive/2017/03/how-a-new-supreme-court-ruling-could-affect-special-education/520662/

• The Federal District Court judge denied the plaintiff's claim stating that, although little progress was made, the small changes in IEP goals did prove that some progress was made.
• A previous court case, Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley, was addressed.
• Parents appealed this claim, stating that FAPE goes beyond making “some progress” and means that children should be academically successful and should be able to contribute to society as a result of their education.

The court must answer this question:

“What should be the level of educational benefit that a school district must provide to a child with exceptionalities that proves they are providing them with a FAPE that is guaranteed by IDEA”?