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Endrew F. v. Douglas County School District

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Supreme Court of the United States
Endrew F. v. Douglas County School District
Reference: 15-827
Issue: Education
Term: 2016
Important Dates
Argued: January 11, 2017
Decided: March 22, 2017
Outcome
Tenth Circuit Court of Appeals vacated and remanded
Vote
8-0 to vacate and remand
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan


Endrew F. v. Douglas County School District is a case argued during the October 2016 term of the U.S. Supreme Court. Argument in the case was held on January 11, 2017. The case came on a writ of certiorari to the United States Court of Appeals for the 10th Circuit. In a unanimous opinion authored by Chief Justice John G. Roberts, the court vacated and remanded the judgment of the Tenth Circuit Court of Appeals. The court held that the Individuals with Disabilities Education Act (IDEA) requires schools to offer an individualized education plan (IEP) that is reasonably calculated to enable a child to progress that is appropriate in light of the child's circumstances. The court declined to create a uniform rule for determining the adequacy of the IEP, but noted that the adequacy of an IEP would depend on the circumstances of the child for whom the IEP was created.

HIGHLIGHTS
  • The case: The Individuals with Disabilities Education Act (IDEA) requires all school districts to provide educational benefits to children with disabilities sufficient to provide them with "free appropriate public education" (FAPE). Endrew F. is challenging the opinion of the Tenth Circuit Court of Appeals affirming a lower court ruling that the Douglas County School District provided him with a FAPE and, as such, Endrew's parents are not entitled for tuition reimbursement and related expenses for private school.
  • The issue: What is the level of educational benefits that school districts must give to children with disabilities in order to provide them with the "free appropriate public education" (FAPE) requirements of the Individuals with Disabilities Education Act (IDEA)?
  • The outcome: The appeal is pending adjudication before the U.S. Supreme Court.


    • In brief: Endrew F. is a minor with autism and attention deficit/hyperactivity disorder (ADHD). The conditions affect his learning and social abilities. From preschool through fourth grade, Endrew attended schools in the Douglas County School District (District) where he received special-education services, including an individualized education plan (IEP) that was designed to accommodate his needs. After his fourth grade year, Endrew's parents rejected the IEP proposed for his fifth grade year and placed him in a private school. The parents sought reimbursement for tuition and related expenses under the Individuals with Disabilities Education Act (IDEA), which permits court-ordered reimbursement if a district violates the requirement for a "free appropriate public education" (FAPE) under the IDEA. Here, a federal district court and the Tenth Circuit Court of Appeals held that the District did not violate the IDEA. Argument in the case was held on January 11, 2017.

    You can review the Tenth Circuit's opinion here.[1]

    Click on the tabs below to learn more about this Supreme Court case.

    Case


    Background

    A federal law, the Individuals with Disabilities Education Act (IDEA), provides federal education funds to state governments provided the states make a "free appropriate public education" (FAPE) available to all children with disabilities. "The central mechanism by which the Act ensures a FAPE for each child is the development and implementation of an individualized education program (IEP)." Based on a 2012 Tenth Circuit precedent, Jefferson County School District R-1 v. Elizabeth E. ex rel. Roxanne B., an IEP is defined as "a detailed written document which describes the student's educational goals for an academic year and establishes a plan to achieve those goals."[1][2] The IEP "must be 'reasonably calculated to enable the child to receive educational benefits.'"[1][3]

    Endrew F., the petitioner, was diagnosed with autism when he was two and with attention deficit/hyperactivity disorder (ADHD) when he was three. According to the Tenth Circuit's opinion in this case, "Drew's autism affects his cognitive functioning, language and reading skills, and his social and adaptive abilities."[4] From preschool through fourth grade, he attended public schools in the Douglas County School District (District) in Colorado. During his time in Douglas County schools, he received special-education services, including an IEP each year. After fourth grade, Endrew's parents, Joseph and Jennifer F., placed their son in a private school, Firefly Autism House, that specializes in educating autistic children. Alleging that the District failed to provide their son with a FAPE, Endrew's parents sought reimbursement from the District for Endrew's private-school tuition and related expenses. Under 20 U.S.C. § 1412(a)(10)(C)(ii),[1]

    “

    If the parents of a child with a disability, who previously received special education and related services under the authority of a public agency, enroll the child in a private elementary school or secondary school without the consent of or referral by the public agency, a court or a hearing officer may require the agency to reimburse the parents for the cost of that enrollment if the court or hearing officer finds that the agency had not made a free appropriate public education available to the child in a timely manner prior to that enrollment. [5]

    		”

    After an three-day procedural hearing before an administrative law judge, the request for reimbursement was denied. A federal district court affirmed the administrative judge's denial. Endrew F., through his parents, appealed to the United States Court of Appeals for the 10th Circuit. In an opinion authored by Chief Judge Timothy Tymkovich, a three-judge panel affirmed the district court judgment.

    In acknowledging that "the only issue is whether the District violated the IDEA by failing to provide Drew with a FAPE," the panel turned to the standard used in the Tenth Circuit to determine if a school district has provided a student with a FAPE. The court employs a two-step analysis, considering "(1) whether the district complied with the Act's procedural requirements, and (2) whether the IEP developed by those procedures is substantively adequate such that it is 'reasonably calculated to enable the child to receive educational benefits' ... If a district has met both the procedural and substantive requirements, it 'has complied with the obligations imposed by Congress and the courts can require no more.'"[1]

    The court recognized that the parents raised two procedural deficiencies: that the District failed to provide the parents with adequate reporting of Endrew's progress and that the District failed to both assess and address Endrew's behavioral needs. The panel, however, held that the parents were aware of Endrew's progress and participated fully in his education. The panel further noted that the record was "filled with examples of the District's consideration of Drew's behavioral issues. Thus, the District complied with federal law ... In sum, we find no procedural defect that amounted to a denial of a FAPE."[1]

    In addressing the petitioners' substantive challenge, while the panel acknowledged that some federal circuit courts require a "meaningful educational benefit," the Tenth Circuit's precedent only requires that "some educational benefit" be provided. By this standard, the panel held that the District's proposed IEP would have provided some educational benefit in that the IEP was "reasonably calculated to enable Drew to receive educational benefits."[1]

    Petitioner's challenge

    Endrew F., the petitioner, is challenging the standard used by the Tenth Circuit Court of Appeals in determining that Douglas County's IEP was reasonably calculated to enable Endrew to receive educational benefits. Endrew F. contends that the standard should require a meaningful educational benefit, not simply some educational benefit.

    Certiorari granted

    On December 22, 2015, Endrew F., the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 10th Circuit. The U.S. Supreme Court granted Endrew F.'s certiorari request on September 29, 2016. Argument in the case was held on January 11, 2017.

    Arguments


    Question presented

    Question presented:

    "What is the level of educational benefit that school districts must confer on children with disabilities to provide them with the free appropriate public education guaranteed by the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq.?"[6]


    Audio

    • Audio of oral argument:[7]




    Transcript

    • Transcript of oral argument:[8]

    Outcome

    Decision

    Chief Justice John G. Roberts delivered the opinion for a unanimous court. In the opinion, the court held that the Individuals with Disabilities Education Act (IDEA) requires schools to offer an individualized education plan (IEP) that is reasonably calculated to enable a child to progress that is appropriate in light of the child's circumstances. The court declined to create a uniform rule for determining the adequacy of the IEP, but noted that the adequacy of an IEP would depend on the circumstances of the child for whom the IEP was created.[9]

    Opinion

    In his opinion for the court, Chief Justice Roberts attempted to provide guidance on how the adequacy of an IEP should be assessed by courts.

    “

    For a child fully integrated in the regular classroom, an IEP typically should ... be 'reasonably calculated to enable the child to achieve passing marks and advance from grade to grade.' ... The goals may differ, but every child should have the chance to meet challenging objectives. Of course this describes a general standard, not a formula. But whatever else can be said about it, this standard is markedly more demanding than the 'merely more than de minimis ' test applied by the Tenth Circuit. It cannot be the case that the Act typically aims for grade-level advancement for children with disabilities who can be educated in the regular classroom, but is satisfied with barely more than de minimis progress for those who cannot. When all is said and done, a student offered an educational program providing 'merely more than de minimis ' progress from year to year can hardly be said to have been offered an education at all. For children with disabilities, receiving instruction that aims so low would be tantamount to 'sitting idly ... awaiting the time when they were old enough to 'drop out.' ... The IDEA demands more. It requires an educational program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances. ...

    We will not attempt to elaborate on what 'appropriate' progress will look like from case to case. It is in the nature of the Act and the standard we adopt to resist such an effort: The adequacy of a given IEP turns on the unique circumstances of the child for whom it was created. This absence of a bright-line rule, however, should not be mistaken for 'an invitation to the courts to substitute their own notions of sound educational policy for those of the school authorities which they review.' ... At the same time, deference is based on the application of expertise and the exercise of judgment by school authorities. The Act vests these officials with responsibility for decisions of critical importance to the life of a disabled child. The nature of the IEP process, from the initial consultation through state administrative proceedings,ensures that parents and school representatives will fully air their respective opinions on the degree of progress a child’s IEP should pursue. ... By the time any dispute reaches court, school authorities will have had a complete opportunity to bring their expertise and judgment to bear on areas of disagreement. A reviewing court may fairly expect those authorities to be able to offer a cogent and responsive explanation for their decisions that shows the IEP is reasonably calculated to enable the child to make progress appropriate in light of his circumstances. [5]

    		”

    Concurring opinions

    There were no concurring opinions filed in this case.

    Dissenting opinions

    There were no dissenting opinions filed in this case.


    The opinion

    Filings

    The court granted Endrew F.'s certiorari request on September 29, 2016.

    Merits filings

    Parties' filings

    The parents of Endrew F., the petitioners, filed a merits brief on November 14, 2016.

    The Douglas County School District, the respondent, filed a merits brief on December 14, 2016.

    Endrew F. and his parents filed a reply brief on the merits on December 30, 2016.

    Amicus curiae filings

    The following groups filed amicus curiae briefs in support of the petitioners, Endrew F. and his parents:

    • Brief of 118 Members of Congress
    • Brief of Advocates for Children of New York et al.
    • Brief of the Council of Parent Attorneys and Advocates et al.
    • Brief of the Council of Texans with Disabilities et al.
    • Brief of the National Association of State Directors of Special Education
    • Brief of the National Center for Special Education in Charter Schools et al.
    • Brief of the National Disability Rights Network et al.
    • Brief of the United States of America
    • Brief of various disability rights organizations

    The following groups filed amicus curiae briefs in support of the respondent, the Douglas County School District:

    • Brief of ASSA, the School Superintendents Association
    • Brief of the Colorado State Board of Education and the Colorado Department of Education
    • Brief of the Great City Schools

    Certiorari filings

    Parties' filings

    • Endrew F., the petitioner, filed a petition for certiorari on December 22, 2015.

    Amicus curiae filings

    The following groups filed amicus curiae briefs in support of granting certiorari.

    • Brief of Autism Speaks and the Public Interest Law Center
    • Brief of the United States of America

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 U.S. Court of Appeals for the Tenth Circuit, Endrew F., a minor, by and through his parents and next friends, Joseph F., and Jennifer F. v. Douglas County School District RE-1, August 25, 2015
    2. ↑ U.S. Court of Appeals for the Tenth Circuit, "Jefferson County School District R-1 v. Elizabeth E. ex rel. Roxanne B.," filed December 28, 2012
    3. ↑ Supreme Court of the United States (via Cornell's LII), "Board of Education of the Hendrick Hudson Central School District Bd. of Ed., Westchester County, et al., Petitioners v. Amy Rowley, by her parents and natural guardians, Clifford and Nancy Rowley etc.," decided June 28, 1982
    4. ↑ Cite error: Invalid <ref> tag; no text was provided for refs named tenth
    5. ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, Endrew F. v. Douglas County School District, September 29, 2016
    7. ↑ Supreme Court of the United States, Endrew F. v. Douglas County School District RE-1, argued January 11, 2017
    8. ↑ Supreme Court of the United States, Endrew F. v. Douglas County School District RE-1, argued January 11, 2017
    9. ↑ Supreme Court of the United States, Endrew F. v. Douglas County School District RE-1, decided March 22, 2017
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