Endrew, Rowley, and What Is an Appropriate Education

By Ana Paula Fabian Freire

This issue of NASET’s Classroom Management series was written by Ana Paula Fabian Freire. The ruling of Endrew F. v. Douglas County School District requires progress that is greater than the de minimis precedent established in the case of Board of Education v. Rowley, where the school district had to demonstrate that the IEP provides student with disabilities reasonable educational benefit. Notably, reasonable was often based on minimal expectations often measured by effort instead of outcomes. In Endrew F., it was clarified that a school must provide and IEP that is reasonably calculated in order for a child to make progress according to the child’s own circumstances, and the child’s educational program must be appropriately ambitious and meet challenging objectives. The term “appropriate” in FAPE has had different interpretations, although it is clear that after Endrew F. the standards were raised in terms of what is considered an appropriate education for students with disabilities. All students with disabilities must have in their IEPs expectations of progress that are appropriate and instruction designed to meet their unique needs.

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