Endrew F. v. Douglas County School District RE1
Facts of the case
Endrew F. is an autistic fifth grade student who was placed in private school because his parents believed his public school education was inadequate. Endrew was placed in Firefly Autism House and his parents sued for reimbursement of Endrew’s private school tuition and related expenses pursuant to the Individuals with Disabilities Act (IDEA). IDEA provides that if a free public school cannot meet the educational needs of a disabled student, the student’s parents may enroll their child in a private school and seek reimbursement for tuition and related expenses.This case first went to an Administrative Law Judge (ALJ) for review. The ALJ rejected Endrew’s parent’s request for reimbursement concluding that Endrew’s public school had provided him with “free appropriate public education” (FAPE) as required by the IDEA. The district court affirmed the ALJ’s ruling and held that Endrew’s parents failed to meet their burden to prove that Endrew was not provided with FAPE. The U.S. Court of Appeals for the Tenth Circuit affirmed.
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 (IDEA)?
(Summary courtesy of oyez.org)
In a unanimous (8-0) opinion delivered by Chief Justice Roberts, the Court held that:
“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.”
The Court vacated the 10th Circuit’s judgment and remanded the case, ordering the 10th Circuit to conduct further proceedings consistent with the Court’s opinion.