Date Published: Jan 1, 2018
Exceptional Children
Turnbull, H.R., Turnbull, A.P., & Cooper, D.H.
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In this article, we analyze the Supreme Court’s decision in Endrew F. v. Douglas County School District RE-1 (2017), interpreting the Individuals with Disabilities Education Act (IDEA) and its provisions creating a right of every student with a disability to have an appropriate education. We compare the Endrew decision with IDEA and the Court’s previous appropriate education decision, Board of Education of the Hendrick Hudson Central School District v. Rowley (1982), on four key concepts: educational program, reasonably calculated, progress, and child’s circumstances. We discuss the case’s implications for systems capacity development and interpret Endrew as a narrative about students’ ethical claim to dignity. [article abstract]

On balance, the Endrew decision strengthens students’ rights on several fronts. The Court in Endrew (a) rejected the “de minimis” interpretation of the Court of Appeals; (b) required careful attention to the student’s “potential for growth”; (c) emphasized that “progress,” not “benefit,” is a metric for appropriateness; (d) declared that a standard not focused on progress “would do little to remedy the pervasive and tragic academic stagnation that prompted Congress to act”; (e) required an “appropriately ambitious” program for students who are not fully integrated into general education classes as evidenced by making grade-tograde progress; and (f) declared that “every child should have the chance to meet challenging objectives.” [excerpt, p.134]