To meet its substantive obligation under the IDEA, a school must offer an individualized education program reasonably calculated to enable a child to make progress appropriate in light of their circumstances.
A student with autism was denied a free appropriate public education when his school district provided an individualized education program that failed to result in meaningful progress. The parents sought reimbursement for private school tuition after the student's academic and functional progress stalled under the district's proposed plans. The court addressed whether the Individuals with Disabilities Education Act requires a school to provide an educational program that offers more than merely de minimis progress. The court holds that to meet its substantive obligation, 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.
137 S. Ct. at 999 Determining the standard for reasonable individualized education programs261 citing cases“reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances.”
- M.R. v. Dist. of Columbia, No. 2025-0556 (D.D.C. July 15, 2026).published (Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
- Lab'y Charter Sch. v. M. S., No. 25-2173 (3d Cir. Apr. 21, 2026).unpublished(To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.)
- Am, No. 2:25-cv-02524 (E.D. Pa. Jan. 23, 2026). Dist. v. M.R., 680 F.3d 260, 279 (3d Cir. 2012) (“[H]earing officers and reviewing courts must continue to assess the appropriateness of [a Plan] on a case-by-case basis”). 90 See Endrew F., 580 U.S. at 399 (noting the “‘reasonably calcula…
- Uhlenkamp v. Dist. of Columbia, No. 2021-2662 (D.D.C. Aug. 8, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. July 30, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. T. v. Dist. of Columbia, No. 2023-0370 (D.D.C. July 9, 2025).published Stated simply, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE wi…
- W. v. Peninsula Sch. Dist., No. 3:24-cv-05820 (W.D. Wash. June 5, 2025).“Any review of an IEP must appreciate that the question is 22 whether the IEP is reasonable, not whether the court regards it as ideal.”
- Philpot v. Dist. of Columbia, No. 2023-0671 (D.D.C. May 6, 2025).published (The ‘reasonably calculated’ qualification reflects a recognition that crafting an appropriate program of education requires a prospective judgment by school officials.)
- G.L. & C.L. v. Verona Boro Bd. of Educ., No. 2:23-cv-00938 (D.N.J. July 26, 2024).unpublished(To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.)
- L.J.B. v. North Rockland Cent. Sch. Dist., No. 7:22-cv-08474 (S.D.N.Y. Apr. 15, 2024).(Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
Show 195 more citing cases
- Lee v. Prince George Cnty. Pub. Sch., No. 8:22-cv-00957 (D. Md. Jan. 31, 2024). See Endrew F., 580 U.S. at 387-88 (“A child’s IEP need not aim for grade-level advancement if that is not a reasonable prospect.”); see also Daniel R.R. v. State Bd. of Educ., 874 F.2d 1036, 1047 (5th Cir. 1989) (“[S]ome handicapped childr…
- Doe v. Vineland City Bd. of Educ., No. 1:19-cv-12154 (D.N.J. Jan. 17, 2024). (To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.)
- Irvine Unified Sch. Dist. v. Sharon Landers, No. 21-55290 (9th Cir. Dec. 26, 2023).unpublished (The IEP must aim to enable the child to make progress.)
- W. v. Upper Darby Sch. Dist., No. 2:22-cv-04347 (E.D. Pa. July 27, 2023). See Endrew F., 580 U.S. at 391 (“The IDEA requires that every IEP… set out ‘measurable annual goals, including academic and functional goals,’ along with a ‘description of how the child's progress toward meeting’ those goals will be gauged…
- Upper Darby Sch. Dist. v. K.W., No. 2:22-cv-04343 (E.D. Pa. July 27, 2023). See Endrew F., 580 U.S. at 391 (“The IDEA requires that every IEP… set out ‘measurable annual goals, including academic and functional goals,’ along with a ‘description of how the child's progress toward meeting’ those goals will be gauged…
- M.S. v. Downingtown Area Sch. Dist., No. 2:20-cv-05085 (E.D. Pa. Oct. 28, 2022). (The IEP must aim to enable the child to make progress” and “progress contemplated by the IEP)
- Osseo Area Schs. v. A.J.T., No. 0:21-cv-01453 (D. Minn. Sept. 13, 2022). (A focus on the particular child is at the core of the IDEA.)
- C. K. v. Bd. of Educ. of Sylvania City Sch. Dist., No. 21-3244 (6th Cir. Sept. 9, 2022).unpublished Applying Endrew F., the district court correctly rejected this order and the legal analysis that supported it. 137 S. Ct. at 989 (“[T]he statement that the Act did not ‘guarantee any particular level of education’ simply reflects the unobj…
- Doucette v. Jacobs, No. 1:15-cv-13193 (D. Mass. July 12, 2022).(Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal. The IEP must aim to enable the child to make progress.)
- R.S. v. Smith, No. 8:20-cv-01300, 2021 WL 3633961 (D. Md. Aug. 17, 2021). (Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
- K. v. Sylvania City Schs., No. 3:19-cv-02753 (N.D. Ohio Feb. 9, 2021). Endrew F., 137 S. Ct. at 1002 (“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 progr…
- D.S. v. Trumbull Bd. of Ed., 975 F.3d 152 (2d Cir. 2020).published (To 12Because we find that the statute of limitations upon which the Board relies does not apply to D.S.’s parents’ IEE request, we need not address D.S.’s related argument that the Board waived any statute of limitatio…)
- Mark K. v. Douglas Cnty. Sch. Dist. RE-1, No. 1:19-cv-01273 (D. Colo. May 29, 2020).(To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress 23 appropriate in light of the child’s circumstances.)
- Colonial Sch. Dist. v. G. K., No. 18-2190 (3d Cir. Feb. 13, 2019).unpublished(Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
- Student, No. 3:25-cv-02066 (D. Or. Aug. 12, 2026). Dist. RE-1, 580 U.S. 386 , 390 (2017) (“In exchange for the funds, a State pledges to comply with a number of statutory conditions.
- Doe v. Canton Bd. of Educ., No. 3:21-cv-00904 (D. Conn. Apr. 30, 2024).([The IDEA] requires an education program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.)
- Killoran v. Westhampton Beach UFSD, No. 21-2647, 2023 WL 4503151 (2d Cir. July 13, 2023).unpublished Id. (emphasis added); see 13 also id. (“If [progressing smoothly through the regular curriculum] is not a reasonable prospect for 14 a child, his IEP need not aim for grade-level advancement.”).
- Does v. Key, No. 4:20-cv-00104 (E.D. Ark. Nov. 19, 2021). (a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances)
- B. v. Smith, No. 8:18-cv-01780 (D. Md. July 9, 2019). (Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
- R. M. v. Gilbert Unified Sch. Dist., No. 17-16722 (9th Cir. Apr. 24, 2019).unpublished(The IDEA demands more [than de minimis progress]. It requires an educational program 2 reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.)
- Doe v. Belchertown Pub. Sch., 347 F. Supp. 3d 90 (D.D.C. 2018).published (Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
- Piquette v. Belchertown Pub. Schs., No. 3:16-cv-30189 (D. Mass. Nov. 13, 2018).(Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.)
- R. S. v. Highland Park Indep Sch Dist, 951 F.3d 319 (5th Cir. 2020).published
- A.T. v. Dist. of Columbia, No. 2016-1086 (D.D.C. May 18, 2021).published
- D.C. v. Klein Indep Sch Dist, No. 20-20339 (5th Cir. June 17, 2021).unpublished
- H.W. v. Comal Indep Sch Dist, 32 F.4th 454 (5th Cir. 2022).published
- Pierre-Noel v. Bridges Pub. Charter Sch., No. 2023-0070 (D.D.C. Apr. 6, 2023).published
- Dragon v. Swampscott Pub. Schs., No. 1:19-cv-10431 (D. Mass. June 23, 2020).
- Whitaker v. Bd. of Educ. for Prince George's Cnty. Pub. Schs., No. 8:19-cv-02488 (D. Md. Aug. 25, 2020).
- Mr & Mrs Catling v. York Sch. Dep't, No. 2:19-cv-00110 (D. Me. Oct. 28, 2020).
- Killoran v. Westhampton Beach UFSD, No. 2:19-cv-03298 (E.D.N.Y. Oct. 11, 2021).
- J.N. v. Oregon Dep't of Educ., No. 6:19-cv-00096 (D. Or. Feb. 5, 2021).
- Moynihan v. West Chester Area Sch. Dist., No. 2:19-cv-00648 (E.D. Pa. Mar. 18, 2022).
- Irish J v. East Stroudsburg Area Sch. Dist., No. 3:19-cv-01926 (M.D. Pa. Aug. 6, 2020).
- Abigail, P. v. Old Forge Sch. Dist., No. 3:21-cv-02033 (M.D. Pa. Mar. 14, 2023).
- Grafton Sch. Dist. v. L, No. 2:19-cv-01179 (E.D. Wis. July 8, 2020).
- L.B. v. Roselle Bd. of Educ., No. 2:18-cv-11588 (D.N.J. June 30, 2025).
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. May 5, 2026).published
- Eileen Esposito v. Ridgefield Park Bd. of Educa, 856 F. App'x 367 (3d Cir. 2021).unpublished
- J.N. v. Jefferson Cnty. Bd. of Educ., 12 F.4th 1355 (11th Cir. 2021).published
- Layna Crofts v. Issaquah Sch. Dist., 22 F.4th 1048 (9th Cir. 2022).published
- Falmouth Sch. Dep't v. Mr. & Mrs. Doe, No. 21-1882P (1st Cir. Aug. 11, 2022).published
- O.P. v. Jefferson Cnty. Bd. of Educ., No. 2:22-cv-00030 (N.D. Ala. Feb. 7, 2023).
- G. v. Harrison Sch. Dist. 2, No. 1:17-cv-01034 (D. Colo. Oct. 2, 2020).
- W. v. Poudre Sch. Dist. R-1, No. 1:19-cv-01270 (D. Colo. July 15, 2022).
- Mandeville v. Dep't of Educ., No. 1:21-cv-00468 (D. Haw. Dec. 29, 2022).
- D. v. Natick Pub. Sch. Dist., No. 1:19-cv-12427 (D. Mass. Dec. 22, 2020).
- Bd. Of Educ. Of Montgomery Cnty. v. S.M., No. 8:20-cv-02301 (D. Md. Mar. 30, 2022).
- B. v. Smith, No. 8:21-cv-00781 (D. Md. May 26, 2022).
- H. v. McKnight, No. 8:21-cv-02297 (D. Md. Aug. 30, 2022).
- Minnetonka Pub. Schs. v. M.L.K., No. 0:20-cv-01036 (D. Minn. Mar. 1, 2021).
- Dawn M. v. Sch. Dist. of the Chathams, No. 2:20-cv-10165 (D.N.J. Dec. 9, 2021).unpublished
- P.F. v. Ocean Twp. Bd. of Educ., No. 3:21-cv-19315 (D.N.J. Sept. 20, 2022).unpublished
- C. v. West Windsor-plainsboro Reg'l Bd. of Educ., No. 3:21-cv-13016 (D.N.J. Nov. 30, 2022).unpublished
- Albuquerque Pub. Schs. Bd. of Educ. v. Armstrong, No. 1:21-cv-00396 (D.N.M. Dec. 13, 2021).
- B.M. v. Pleasantville Union Free Sch. Dist., No. 7:20-cv-02192-KMK, 2021 WL 4392281 (S.D.N.Y. Sept. 24, 2021).
- Isabelle K. v. Manheim Twp. Sch. Dist., No. 5:19-cv-05517 (E.D. Pa. Jan. 26, 2022).
- Downingtown Area Sch. Dist. v. D.s, No. 2:20-cv-00892, 2022 WL 523563 (E.D. Pa. Feb. 22, 2022).
- J. v. Colonial Sch. Dist., No. 2:19-cv-00652 (E.D. Pa. Feb. 24, 2022).
- M. v. Wallingford-swarthmore Sch. Dist., No. 2:21-cv-01926 (E.D. Pa. Sept. 21, 2022).
- C.S. v. Johnston Sch. Dep't, No. 1:19-cv-00637 (D.R.I. Mar. 9, 2021).
- K.B. v. Memphis-Shelby Cnty. Schs., No. 2:22-cv-02464 (W.D. Tenn. Mar. 12, 2024).
- E.E. v. Ridgefield Park Bd. of Educ., No. 2:19-cv-01221, 2020 WL 3097473 (D.N.J. June 11, 2020).unpublished
- D.C. v. Klein Indep. Sch. Dist., No. 4:19-cv-00021 (S.D. Tex. May 29, 2020).
- A.H. v. Arlington Cnty. Sch. Bd., No. 1:20-cv-00981 (E.D. Va. Apr. 6, 2021).
- XXXXXX v. Arlington Cnty. Sch. Bd., No. 1:20-cv-00817 (E.D. Va. June 7, 2021).
- H.L. v. Tri-Valley Sch. Dist., No. 3:20-cv-01125 (M.D. Pa. Mar. 14, 2023).
- Mason G. v. W. Wayne Sch. Dist., No. 3:22-cv-00004 (M.D. Pa. Sept. 6, 2024).
- G.L. v. Dist. of Columbia, No. 2024-0280 (D.D.C. Aug. 22, 2025).published
- R.F., No. 1:24-cv-03117 (S.D.N.Y. Sept. 22, 2025).
- Hilyer v. Elmore Cnty. Bd. of Educ., No. 2:22-cv-00705 (M.D. Ala. Feb. 16, 2024).
- J. v. Kennett Consol. Sch. Dist., No. 2:21-cv-04495 (E.D. Pa. Feb. 1, 2023).
- F. v. Upper Darby Sch. Dist., No. 2:21-cv-05653 (E.D. Pa. Apr. 6, 2023).
- ABL v. Providence Pub. Schs., No. 1:22-cv-00379 (D.R.I. Nov. 3, 2023).
- I.S. v. Fulton Cnty. Sch. Dist., No. 23-13456 (11th Cir. Oct. 31, 2024).unpublished
- Mantua Twp. Bd. of Educ. v. E.K., No. 1:22-cv-07496 (D.N.J. Sept. 30, 2023).
- S.M. v. Chichester Sch. Dist., No. 2:21-cv-04266 (E.D. Pa. Oct. 7, 2024).
- Moonsammy v. Banks, No. 1:23-cv-10491 (S.D.N.Y. Mar. 7, 2025).
- Lab'y CHARTER Sch. v. MRS, No. 2:21-cv-05538 (E.D. Pa. May 27, 2025).
- North East Indep Sch Dist v. M., No. 24-50833 (5th Cir. Dec. 23, 2025).published
- Pitta v. Medeiros, No. 1:22-cv-11641, 2023 WL 3572391 (D. Mass. May 19, 2023).
- Abigail P. v. Old Forge Sch. Dist., 105 F.4th 57 (3d Cir. 2024).published
- J.T. v. Dist. of Columbia, No. 2024-1400 (D.D.C. July 21, 2025).published
- Spurwink Servs. Inc v. Doe, No. 2:25-cv-00026 (D. Me. Aug. 19, 2025).
- James F. v. Clear Creek Indep. Sch. Dist., No. 4:23-cv-02063 (S.D. Tex. Mar. 3, 2026).
- C.E., No. 8:24-cv-01941 (D. Md. Mar. 26, 2026).
- Lausd v. A. O., No. 22-55204 (9th Cir. Feb. 15, 2024).published
- William A. v. Clarksville-Montgomery Cnty. Sch. Sys., 127 F.4th 656 (6th Cir. 2025).published
- J.M. v. Genesee Intermediate Sch. Dist., No. 2:23-cv-12896 (E.D. Mich. Sept. 30, 2025).
- R.S. & R.S. v. Lower Merion Sch. Dist., 660 F. Supp. 3d 284 (E.D. Pa. 2023).published
- A. v. Clarksville-Montgomery Cnty. Schs., No. 3:23-cv-00912 (M.D. Tenn. May 24, 2024).
- AA v. Montgomery Cnty. Pub. Schs., No. 8:24-cv-01675 (D. Md. Sept. 12, 2025).
- E.W., No. 5:25-cv-02904 (E.D. Pa. Feb. 17, 2026).
- J.T. v. Denver Pub. Schs., No. 1:21-cv-01227 (D. Colo. Jan. 30, 2023).
- C. v. Pennsbury Sch. Dist., No. 2:22-cv-04080 (E.D. Pa. Aug. 18, 2023).
- P. v. McKnight, No. 8:23-cv-01680 (D. Md. July 29, 2024).
- Zachary J. v. Colonial Sch. Dist., No. 22-1509, 2024 U.S. App. LEXIS 2187 (3d Cir. Jan. 31, 2024).unpublished
- A.D. & M.D. v. Upper Merion Area Sch. Dist., No. 2:21-cv-05468, 2022 WL 16553379 (E.D. Pa. Oct. 28, 2022).
- J-D. v. Dist. of Columbia, No. 2024-0707 (D.D.C. Sept. 22, 2025).published
- B.B. v. Dist. of Columbia, No. 2020-2467, 2022 WL 834146 (D.D.C. Mar. 21, 2022).published
- Caldara v. Boulder Valley Sch. Dist. RE-2, No. 1:22-cv-00564 (D. Colo. Dec. 21, 2023).
- A.C. v. Brandywine Sch. Dist., No. 1:21-cv-00713 (D. Del. Feb. 10, 2023).
- G. D. v. Swampscott Pub. Schs., No. 20-2114P (1st Cir. Feb. 22, 2022).published
- Minnetonka Pub. Schs. v. M.L.K., 42 F.4th 847 (8th Cir. 2022).published
- S.S. v. Cobb Cnty. Sch. Dist., No. 1:18-cv-00313 (N.D. Ga. Mar. 1, 2021).
- Fragnito v. Bd. of Educ. of the Suffern Cent. Sch. Dist., No. 7:19-cv-01598 (S.D.N.Y. July 21, 2020).
- Cent. Bucks Sch. Dist. v. Q.M., No. 2:22-cv-01128 (E.D. Pa. Sept. 12, 2022).
- Wishard v. Waynesboro Area Sch. Dist., No. 1:18-cv-01665 (M.D. Pa. Aug. 21, 2020).
- Perez v. Weslaco Indep. Sch. Dist., No. 7:21-cv-00352 (S.D. Tex. Aug. 24, 2022).
- Mr & Ms Doe v. Portland Pub. Schs., No. 2:20-cv-00461 (D. Me. July 14, 2022).
- P v. Parkland Sch. Dist., No. 5:20-cv-04447 (E.D. Pa. Aug. 25, 2021).
- C.B. v. Nazareth Area Sch. Dist. Sch. Dist., No. 5:24-cv-00844 (E.D. Pa. Jan. 6, 2025).
- Butte Sch. Dist. No. 1 v. C.S., No. 19-35134 (9th Cir. May 27, 2020).unpublished
- ISD No. 283 v. E.M.D.H., 960 F.3d 1073 (8th Cir. 2020).published
- S. M. v. Dist. of Columbia, No. 2019-2096 (D.D.C. Dec. 8, 2020).published
- Holman v. Dist. of Columbia, No. 2019-2600 (D.D.C. Dec. 14, 2020).published
- John Fenicle v. Indiana Sch. for the Deaf (mem. dec.), 163 N.E.3d 320 (Ind. Ct. App. 2020).published
- K.B. v. Katonah Lewisboro Union Free Sch. Dist., No. 19-3946-cv (2d Cir. Feb. 26, 2021).unpublished
- D. D. v. Lausd, 18 F.4th 1043 (9th Cir. 2021).published
- White v. Columbia, No. 2020-3821 (D.D.C. Mar. 31, 2022).published
- J.P. v. Belton Sch. Dist. No. 124, 40 F.4th 887 (8th Cir. 2022).published
- D.O. v. Escondido Union Sch. Dist., 59 F.4th 394 (9th Cir. 2023).published
- W.G. v. Columbia, No. 2020-2806 (D.D.C. Mar. 22, 2023).published
- Dist. of Columbia Int'l Pub. Charter Sch. v. Lemus, 660 F. Supp. 3d 1 (D.D.C. 2023).published
- I. K. v. Manheim Twp. Sch. Dist., No. 22-1347 (3d Cir. May 15, 2023).unpublished
- Judith Steckelberg v. Chamberlain Sch. Dist., 77 F.4th 1167 (8th Cir. 2023).published
- Perez v. Weslaco Indep Sch Dist, No. 22-40634 (5th Cir. Aug. 31, 2023).unpublished
- J.T. v. Dist. of Columbia, No. 2021-3002 (D.D.C. Dec. 4, 2023).published
- Briscoe v. Dist. of Columbia, No. 2022-3365 (D.D.C. Mar. 31, 2024).published
- N. D. v. Chris Reykdal, 102 F.4th 982 (9th Cir. 2024).published
- T.T. v. Jefferson Cnty. Bd. of Educ., No. 2:19-cv-01965 (N.D. Ala. Nov. 23, 2020).
- Teters v. Peoria Unified Sch. Dist., No. 2:19-cv-05038 (D. Ariz. Sept. 30, 2020).
- R. v. Greenwich Bd. of Educ., No. 3:21-cv-00873 (D. Conn. May 31, 2023).
- A. K. v. Dep't of Educ., No. 1:21-cv-00127 (D. Haw. Dec. 7, 2021).
- K.P. v. Dep't of Educ., No. 1:22-cv-00267 (D. Haw. Apr. 13, 2023).
- Chicago Teachers Union v. DeVos, 468 F. Supp. 3d 974 (N.D. Ill. 2020).published
- G.T. v. David Rust, No. 2:21-cv-00138 (E.D. Ky. Oct. 5, 2022).
- S.F. v. Smith, No. 8:19-cv-02207 (D. Md. Aug. 3, 2022).
- G. v. McKnight, No. 8:22-cv-00494 (D. Md. Jan. 27, 2023).
- C. v. McKnight, No. 8:23-cv-02019 (D. Md. June 17, 2024).
- Indep. Sch. Dist. No. 283 v. E.M.D.H, No. 0:18-cv-00935 (D. Minn. May 3, 2021).
- J.P. v. Belton Sch. Dist. No. 124, No. 4:20-cv-00189 (W.D. Mo. Aug. 13, 2021).
- Gloucester Twp. Bd. of Educ. v. E.N., No. 1:22-cv-06568 (D.N.J. Feb. 7, 2024).
- Garcia v. Bd. of Educ. of Gallup-McKinley Cnty. Schs., No. 1:16-cv-01337 (D.N.M. Mar. 27, 2020).
- Gallup-McKinley Cnty. Schs. Bd. of Educ. v. Garcia, No. 1:16-cv-01336 (D.N.M. Mar. 27, 2020).
- Preciado v. Bd. of Educ. of Clovis Mun. Schs., 443 F. Supp. 3d 1289 (D.N.M. 2020).published
- W.T. v. Douglas Cnty. Sch. Dist., No. 3:21-cv-00242 (D. Nev. Aug. 11, 2023).
- Rivas v. Banks, No. 1:22-cv-10007, 2023 WL 8188069 (S.D.N.Y. Nov. 27, 2023).
- Dougall v. Copley-Fairlawn City Sch. Dist. Bd. of Educ., No. 5:17-cv-01664, 2020 WL 435385 (N.D. Ohio Jan. 28, 2020).
- Price v. Commonwealth Charter Academy - Cyber, No. 2:19-cv-01590 (E.D. Pa. Mar. 24, 2020).
- Montgomery Cnty. Intermediate Unit No. 23 v. A.F., 506 F. Supp. 3d 293 (E.D. Pa. 2020).published
- N.P. v. Pleasant Valley Sch. Dist., No. 3:22-cv-00843 (M.D. Pa. Sept. 30, 2023).
- G.M. v. William J. Barnes, No. 21-1247 (4th Cir. Sept. 4, 2024).published
- W.T. v. Douglas Cnty. Sch. Dist., No. 3:21-cv-00242 (D. Nev. Sept. 20, 2023).
- Lignos-Lopez v. Servicios de Terapia Educativa Girasol, Inc., No. 3:22-cv-01419 (D.P.R. Aug. 23, 2024).
- D.H. v. Fairfax Cnty. Sch. Bd., No. 1:19-cv-01342 (E.D. Va. Jan. 19, 2021).
- A.P. v. Sch. Bd. of Fairfax Cnty., No. 1:21-cv-00504 (E.D. Va. Apr. 13, 2022).
- J.L v. Dep't of Educ., No. 1:24-cv-01926 (S.D.N.Y. Nov. 25, 2024).
- J.M. v. Christina Sch. Dist., No. 1:23-cv-00559 (D. Del. Dec. 17, 2024).
- B.Z. v. Hewlett-Woodmere Union Free Sch. Dist., No. 2:23-cv-01759 (E.D.N.Y. Jan. 27, 2025).
- Thomason v. Banks, No. 1:23-cv-08654 (S.D.N.Y. Jan. 27, 2025).
- Q.G. v. Brandywine Sch. Dist., No. 1:23-cv-00905 (D. Del. Feb. 14, 2025).
- K.G. v. Baltimore City Pub. Schs., No. 1:23-cv-01002 (D. Md. June 17, 2025).
- Boone v. Rankin Cnty., 140 F.4th 697 (5th Cir. 2025).published
- Mobley v. Lab'y Charter Sch., No. 2:24-cv-02267 (E.D. Pa. Sept. 11, 2025).
- E.B. v. Dist. of Columbia, No. 2024-0663 (D.D.C. Oct. 8, 2025).published
- R.m, No. 2:23-cv-00009 (E.D. Ky. Dec. 8, 2025).
- A.C., No. 1:25-cv-00228 (D. Haw. Mar. 24, 2026).
- N. T. v. Galesburg Cmty. Unit Sch. Dist. No. 205, 174 F.4th 1044 (7th Cir. 2026).published
- Coleman v. Dist. of Columbia, No. 2024-3598 (D.D.C. May 12, 2026).published
- Ibrahim Alzandani v. Hamtramck Pub. Schs., 176 F.4th 455 (6th Cir. 2026).published
- S. M. v. Chichester Sch. Dist., No. 25-2750 (3d Cir. June 15, 2026).unpublished
- Donohue, No. 1:22-cv-08998 (S.D.N.Y. June 8, 2026).
- M.O., No. 3:25-cv-06127 (D.N.J. Aug. 17, 2026).unpublished
- H.R. v. Dist. of Columbia, No. 2021-1856 (D.D.C. Mar. 29, 2024).published
- Wong v. Bd. of Educ., 478 F. Supp. 3d 229 (D. Conn. 2020).published
- S.S. v. Bd. of Educ. of Harford Cnty., 498 F. Supp. 3d 761 (D. Md. 2020).published
- J.P. v. McKnight, No. 8:21-cv-02427 (D. Md. Sept. 29, 2022).
- C.K. v. Baltimore City Bd. of Sch. Commissioners, No. 1:22-cv-00804 (D. Md. May 31, 2023).
- Coleman v. Wake Cnty. Bd. of Educ., No. 5:17-cv-00295 (E.D.N.C. Feb. 3, 2020).
- Bouabid v. Charlotte Mecklenburg Schs. Bd. of Educ., No. 3:19-cv-00030 (W.D.N.C. Dec. 10, 2021).
- Northfield City Bd. of Educ. v. K.S., No. 1:19-cv-09582 (D.N.J. June 3, 2020).unpublished
- Bd. of Educ. of the Wappingers Cent. Sch. Dist. v. D.M., No. 7:19-cv-01730 (S.D.N.Y. Jan. 30, 2020).
- S.K. v. City Sch. Dist. of the City of New York, No. 1:17-cv-06043 (S.D.N.Y. Mar. 13, 2020).
- Yeger v. East Ramapo Cent. Sch. Dist., No. 7:21-cv-06822 (S.D.N.Y. Nov. 7, 2022).
- J.D. v. Rye Neck Union Free Sch. Dist., No. 7:22-cv-03039 (S.D.N.Y. Feb. 7, 2023).
- Steckelberg v. Chamberlain Sch. Dist., No. 4:21-cv-04147 (D.S.D. Nov. 30, 2022).
- Chaya Loffman v. California Dep't of Educ., 119 F.4th 1147 (9th Cir. 2024).published
- R.S. v. McKnight, No. 8:23-cv-00838 (D. Md. July 18, 2024).
- Bryant v. Dayton Indep. Sch. Dist., No. 4:21-cv-01547, 2021 WL 3555947 (S.D. Tex. Aug. 11, 2021).
- L.C. v. Arlington Cnty. Sch. Bd., No. 1:20-cv-01177 (E.D. Va. June 24, 2022).
- M.B. v. Fairfax Cnty. Sch. Bd., No. 1:22-cv-00930 (E.D. Va. Aug. 22, 2023).
- C.D. v. Arlington Sch. Bd., No. 1:23-cv-01627 (E.D. Va. Jan. 30, 2025).
- Cornett v. Banks, No. 1:23-cv-06893 (S.D.N.Y. Mar. 5, 2025).
- B. v. Bd. of Educ. Hinsdale Twp., No. 1:24-cv-12218 (N.D. Ill. June 12, 2025).
137 S. Ct. at 1001 Determining adequacy of individualized education program84 citing casesholding that the IDEA “requires an educational program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances
- Maggie J. v. Donegal Sch. Dist., No. 5:20-cv-02782 (E.D. Pa. June 30, 2021). Op. at 18; but see Endrew F., 137 S. Ct. at 1000 (“the procedures are there for a reason, and their focus provides insight into what it means, for purposes of the FAPE definition, to ‘meet the unique needs’ of a child with a disability”).…
- Osseo Area Schs. v. A.J.T., No. 0:21-cv-01453 (D. Minn. Sept. 13, 2022). No. 623, 31 IDELR ¶ 17; Endrew F., 137 S. Ct. at 999 (“A focus on the particular child is at the core of the IDEA.”).
- C. K. v. Bd. of Educ. of Sylvania City Sch. Dist., No. 21-3244 (6th Cir. Sept. 9, 2022).unpublished Applying Endrew F., the district court correctly rejected this order and the legal analysis that supported it. 137 S. Ct. at 989 (“[T]he statement that the Act did not ‘guarantee any particular level of education’ simply reflects the unobj…
- K. v. Sylvania City Schs., No. 3:19-cv-02753 (N.D. Ohio Feb. 9, 2021). Endrew F., 137 S. Ct. at 1002 (“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 progr…
- Jacquie Albright v. Mountain Home Sch. Dist., 926 F.3d 942 (8th Cir. 2019).published(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.)
- E. by R. Next Friend E. R. v. Spring Branch Indep. Sch. Dist., 909 F.3d 754 (5th Cir. 2018).published Id. at 1000 ("standard [established in Endrew F. ] is markedly more demanding than the 'merely more than de minimis ' test applied by the Tenth Circuit").
- Johnson v. Boston Pub. Schs., 906 F.3d 182 (1st Cir. 2018).published([T]he IDEA demands .... an educational program reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances.)
- Smith v. Dist. of Columbia, No. 2016-1386 (D.D.C. Sept. 28, 2018).published ([A]dequacy . . . turns on the unique circumstances of the child.)
- Does v. Key, No. 4:20-cv-00104 (E.D. Ark. Nov. 19, 2021). RE-1, 137 S.Ct. 988 , 999 (2017) (“a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances”).
- B. v. Smith, No. 8:18-cv-01780 (D. Md. July 9, 2019). Dist. RE-1, 137 S. Ct. 988 , 999 (2017) (“Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.”).
Show 73 more citing cases
- Z. B. v. D.C., No. 16-7113 (D.C. Cir. May 1, 2018).published
- Middleton v. Dist. of Columbia, No. 2017-0088 (D.D.C. June 4, 2018).published
- R. S. v. Highland Park Indep Sch Dist, 951 F.3d 319 (5th Cir. 2020).published
- A.T. v. Dist. of Columbia, No. 2016-1086 (D.D.C. May 18, 2021).published
- D.C. v. Klein Indep Sch Dist, No. 20-20339 (5th Cir. June 17, 2021).unpublished
- Brandywine Heights Area Sch. Dist. v. B.M. ex rel. B.M., 248 F. Supp. 3d 618 (E.D. Pa. 2017).published
- Endrew F. v. Douglas Cnty. Sch. Dist. Re 1, 290 F. Supp. 3d 1175 (D. Colo. 2018).published
- Dragon v. Swampscott Pub. Schs., No. 1:19-cv-10431 (D. Mass. June 23, 2020).
- Falmouth Sch. Dep't v. Mr & Mrs Doe, No. 2:20-cv-00214 (D. Me. Sept. 29, 2021).
- Killoran v. Westhampton Beach UFSD, No. 2:19-cv-03298 (E.D.N.Y. Oct. 11, 2021).
- AR & KR v. Katonah Lewisboro Union Free Sch. Dist., No. 7:18-cv-09938 (S.D.N.Y. Nov. 21, 2019).
- Perkiomen Valley Sch. Dist. v. S.D., No. 2:18-cv-02093 (E.D. Pa. Sept. 24, 2019).
- Perkiomen Valley Sch. Dist. v. R.B., 533 F. Supp. 3d 233 (E.D. Pa. 2021).published
- Moynihan v. West Chester Area Sch. Dist., No. 2:19-cv-00648 (E.D. Pa. Mar. 18, 2022).
- Abigail, P. v. Old Forge Sch. Dist., No. 3:21-cv-02033 (M.D. Pa. Mar. 14, 2023).
- Grafton Sch. Dist. v. L, No. 2:19-cv-01179 (E.D. Wis. July 8, 2020).
- Adams v. Dist. of Columbia, No. 2017-1816 (D.D.C. Jan. 29, 2018).published
- Pavelko v. Dist. of Columbia, No. 2016-1765 (D.D.C. Feb. 13, 2018).published
- E.F. v. Newport Mesa Unified Sch. Dist, No. 15-56452 (9th Cir. Feb. 14, 2018).unpublished
- Mr. & Mrs. P. v. West Hartford Bd. of Educ., No. 16-3618 (2d Cir. Mar. 23, 2018).published
- J.B. v. Dist. of Columbia Pub. Schs., No. 2017-1298 (D.D.C. Sept. 6, 2018).published
- Shaw v. Dist. of Columbia, No. 2017-0738 (D.D.C. Feb. 8, 2019).published
- L.J. v. Sch. Bd. of Broward Cnty., 927 F.3d 1203 (11th Cir. 2019).published
- Gaston v. Dist. of Columbia, No. 2018-1703 (D.D.C. Aug. 5, 2019).published
- William v. v. Copperas Cove Indep Sch Dist, No. 19-51046 (5th Cir. Sept. 14, 2020).unpublished
- J.T. v. Dist. of Columbia, 496 F. Supp. 3d 190 (D.D.C. 2020).published
- Eileen Esposito v. Ridgefield Park Bd. of Educa, 856 F. App'x 367 (3d Cir. 2021).unpublished
- J.N. v. Jefferson Cnty. Bd. of Educ., 12 F.4th 1355 (11th Cir. 2021).published
- Layna Crofts v. Issaquah Sch. Dist., 22 F.4th 1048 (9th Cir. 2022).published
- Mr. & Ms. Doe v. Portland Pub. Schs., 30 F.4th 85 (1st Cir. 2022).published
- T.M. v. Quakertown Cmty. Sch. Dist., 251 F. Supp. 3d 792 (E.D. Pa. 2017).published
- D.S. v. Trumbull Bd. of Educ., 357 F. Supp. 3d 166 (D. Conn. 2019).published
- Falmouth Sch. Dep't v. Mr. & Mrs. Doe, No. 21-1882P (1st Cir. Aug. 11, 2022).published
- Enter. City Bd. of Educ. v. S.S., No. 1:19-cv-00748 (M.D. Ala. June 12, 2020).
- Jefferson Cnty. Bd. of Educ., The v. S., No. 2:19-cv-00727 (N.D. Ala. Oct. 3, 2019).
- O.P. v. Jefferson Cnty. Bd. of Educ., No. 2:22-cv-00030 (N.D. Ala. Feb. 7, 2023).
- L.B. v. Kyrene Elementary Dist. No. 28, No. 2:17-cv-03316 (D. Ariz. Sept. 4, 2019).
- Albright v. Mountain Home Sch. Dist., No. 3:17-cv-03075 (W.D. Ark. Nov. 5, 2018).
- B.W. v. Denver Cnty. Sch. Dist. No. 1, No. 1:17-cv-02462 (D. Colo. Sept. 25, 2019).
- G. v. Harrison Sch. Dist. 2, No. 1:17-cv-01034 (D. Colo. Oct. 2, 2020).
- W. v. Poudre Sch. Dist. R-1, No. 1:19-cv-01270 (D. Colo. July 15, 2022).
- Mandeville v. Dep't of Educ., No. 1:21-cv-00468 (D. Haw. Dec. 29, 2022).
- Cooper v. Sch. City of Hammond, No. 2:21-cv-00072 (N.D. Ind. Sept. 8, 2023).
- D. v. Natick Pub. Sch. Dist., No. 1:19-cv-12427 (D. Mass. Dec. 22, 2020).
- Bd. Of Educ. Of Montgomery Cnty. v. S.M., No. 8:20-cv-02301 (D. Md. Mar. 30, 2022).
- B. v. Smith, No. 8:21-cv-00781 (D. Md. May 26, 2022).
- H. v. McKnight, No. 8:21-cv-02297 (D. Md. Aug. 30, 2022).
- Minnetonka Pub. Schs. v. M.L.K., No. 0:20-cv-01036 (D. Minn. Mar. 1, 2021).
- Torres v. Sampson Cnty. Bd. of Educ., No. 7:22-cv-00099 (E.D.N.C. Dec. 14, 2022).
- J. W. v. Medford Lakes Bd. of Educ., No. 1:19-cv-20589 (D.N.J. Aug. 18, 2021).
- Dawn M. v. Sch. Dist. of the Chathams, No. 2:20-cv-10165 (D.N.J. Dec. 9, 2021).unpublished
- P.F. v. Ocean Twp. Bd. of Educ., No. 3:21-cv-19315 (D.N.J. Sept. 20, 2022).unpublished
- C. v. West Windsor-plainsboro Reg'l Bd. of Educ., No. 3:21-cv-13016 (D.N.J. Nov. 30, 2022).unpublished
- Albuquerque Pub. Schs. Bd. of Educ. v. Armstrong, No. 1:21-cv-00396 (D.N.M. Dec. 13, 2021).
- Las Cruces Pub. Schs. v. Martos, No. 2:22-cv-00219 (D.N.M. Apr. 25, 2024).
- B.M. v. Pleasantville Union Free Sch. Dist., No. 7:20-cv-02192-KMK, 2021 WL 4392281 (S.D.N.Y. Sept. 24, 2021).
- Price v. Commonwealth Charter Academy Cyber Sch., No. 2:17-cv-05790 (E.D. Pa. Sept. 12, 2019).
- Downingtown Area Sch. Dist. v. G.W., No. 2:19-cv-05424, 2020 WL 5981902 (E.D. Pa. Oct. 8, 2020).
- Montgomery Cnty. Intermediate Unit No. 23 v. K.S., No. 2:20-cv-02330 (E.D. Pa. June 29, 2021).
- O. v. Sch. Dist. of Philadelphia, No. 2:20-cv-01991 (E.D. Pa. Dec. 29, 2021).
- Isabelle K. v. Manheim Twp. Sch. Dist., No. 5:19-cv-05517 (E.D. Pa. Jan. 26, 2022).
- Downingtown Area Sch. Dist. v. D.s, No. 2:20-cv-00892, 2022 WL 523563 (E.D. Pa. Feb. 22, 2022).
- J. v. Colonial Sch. Dist., No. 2:19-cv-00652 (E.D. Pa. Feb. 24, 2022).
- M. v. Wallingford-swarthmore Sch. Dist., No. 2:21-cv-01926 (E.D. Pa. Sept. 21, 2022).
- C.S. v. Johnston Sch. Dep't, No. 1:19-cv-00637 (D.R.I. Mar. 9, 2021).
- A.W. v. Tennessee Dep't of Educ., No. 3:20-cv-00076 (E.D. Tenn. Sept. 28, 2022).
- K.B. v. Memphis-Shelby Cnty. Schs., No. 2:22-cv-02464 (W.D. Tenn. Mar. 12, 2024).
- Sampson Cnty. Bd. of Educ. v. Torres, No. 7:22-cv-00100 (E.D.N.C. Dec. 14, 2022).
- E.E. v. Ridgefield Park Bd. of Educ., No. 2:19-cv-01221, 2020 WL 3097473 (D.N.J. June 11, 2020).unpublished
- D.C. v. Klein Indep. Sch. Dist., No. 4:19-cv-00021 (S.D. Tex. May 29, 2020).
- A.H. v. Arlington Cnty. Sch. Bd., No. 1:20-cv-00981 (E.D. Va. Apr. 6, 2021).
- XXXXXX v. Arlington Cnty. Sch. Bd., No. 1:20-cv-00817 (E.D. Va. June 7, 2021).
- W.S. v. Edmonds Sch. Dist., No. 2:21-cv-00390 (W.D. Wash. July 6, 2022).
137 S. Ct. at 994 Defining the individualized education program requirements56 citing cases“the means by which special education and related services are 'tailored to the unique needs' of a particular child.”
- Frazier-jones, No. 2:25-cv-00280 (E.D. Pa. Nov. 26, 2025). (The IEP must also describe the ‘special education and related services . . . that will be provided’ so that the child may ‘advance appropriately toward attaining the annual goals[.]’)
- Uhlenkamp v. Dist. of Columbia, No. 2021-2662 (D.D.C. Aug. 8, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. July 30, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. T. v. Dist. of Columbia, No. 2023-0370 (D.D.C. July 9, 2025).published Stated simply, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE wi…
- Philpot v. Dist. of Columbia, No. 2023-0671 (D.D.C. May 6, 2025).published Putting these principles together, then, “[t]he key inquiry regarding an IEP’s substantive adequacy is whether, taking account of what the school knew or reasonably should have known of a student’s needs at the time, the IEP it offered was…
- Osseo Area Schs. v. A.J.T., No. 0:21-cv-01453 (D. Minn. Sept. 13, 2022). No. 623, 31 IDELR ¶ 17; Endrew F., 137 S. Ct. at 999 (“A focus on the particular child is at the core of the IDEA.”).
- D.S. v. Trumbull Bd. of Ed., 975 F.3d 152 (2d Cir. 2020).published See Endrew F., 137 S. Ct. at 999 (“To 12Because we find that the statute of limitations upon which the Board relies does not apply to D.S.’s parents’ IEE request, we need not address D.S.’s related argument that the Board waived any statut…
- Mr F v. Msad 35, No. 2:20-cv-00220 (D. Me. May 21, 2021). Dist. RE-1, 137 S. Ct. 988 , 1000 n.2 (2017) (declining to hold that a disabled child who is advancing from grade to grade is automatically considered to be receiving a FAPE); Indep.
- Smith v. Montgomery Cnty. Pub. Schs., No. 8:19-cv-02052 (D. Md. Mar. 27, 2020).“at the conclusion of the administrative process, the losing party may seek redress in state or federal court.”
- R.F. v. Cecil Cnty. Pub. Schs., 919 F.3d 237 (4th Cir. 2019).published “the iep is the centerpiece of the idea's education delivery system for disabled children.”
Show 46 more citing cases
- A.T. v. Dist. of Columbia, No. 2016-1086 (D.D.C. May 18, 2021).published
- Whitaker v. Bd. of Educ. for Prince George's Cnty. Pub. Schs., No. 8:19-cv-02488 (D. Md. Aug. 25, 2020).
- Mr & Mrs Catling v. York Sch. Dep't, No. 2:19-cv-00110 (D. Me. Oct. 28, 2020).
- Killoran v. Westhampton Beach UFSD, No. 2:19-cv-03298 (E.D.N.Y. Oct. 11, 2021).
- AR & KR v. Katonah Lewisboro Union Free Sch. Dist., No. 7:18-cv-09938 (S.D.N.Y. Nov. 21, 2019).
- Abigail, P. v. Old Forge Sch. Dist., No. 3:21-cv-02033 (M.D. Pa. Mar. 14, 2023).
- Amanda P. & Casey P. v. Copperas Cove Indep. Sch. Dist., No. 6:19-cv-00197 (W.D. Tex. Apr. 14, 2020).
- Shaw v. Dist. of Columbia, No. 2017-0738 (D.D.C. Feb. 8, 2019).published
- J.N. v. Jefferson Cnty. Bd. of Educ., 12 F.4th 1355 (11th Cir. 2021).published
- D.S. v. Trumbull Bd. of Educ., 357 F. Supp. 3d 166 (D. Conn. 2019).published
- Falmouth Sch. Dep't v. Mr. & Mrs. Doe, No. 21-1882P (1st Cir. Aug. 11, 2022).published
- Minnetonka Pub. Schs. v. M.L.K., No. 0:20-cv-01036 (D. Minn. Mar. 1, 2021).
- J. W. v. Medford Lakes Bd. of Educ., No. 1:19-cv-20589 (D.N.J. Aug. 18, 2021).
- B.M. v. Pleasantville Union Free Sch. Dist., No. 7:20-cv-02192-KMK, 2021 WL 4392281 (S.D.N.Y. Sept. 24, 2021).
- J.T. v. Dist. of Columbia, No. 2024-1400 (D.D.C. July 21, 2025).published
- Jacobs v. Salt Lake City Sch. Dist., 154 F.4th 790 (10th Cir. 2025).published
- B.B. v. Dist. of Columbia, No. 2020-2467, 2022 WL 834146 (D.D.C. Mar. 21, 2022).published
- F. v. Bd. of Educ. of Chicago Pub. Sch. Dist. 299, No. 1:22-cv-02608 (N.D. Ill. June 2, 2022).
- Lauren C. v. Lewisville Indep. Sch. Dist., 904 F.3d 363 (5th Cir. 2018).published
- W.S. v. Dist. of Columbia, 502 F. Supp. 3d 102 (D.D.C. 2020).published
- G. D. v. Swampscott Pub. Schs., No. 20-2114P (1st Cir. Feb. 22, 2022).published
- Jones v. United States, No. 21-2291 (Fed. Cl. June 30, 2022).unpublished
- G. v. Harrison Sch. Dist. No. 2, 40 F.4th 1186 (10th Cir. 2022).published
- Minnetonka Pub. Schs. v. M.L.K., 42 F.4th 847 (8th Cir. 2022).published
- Hernandez v. Lujan Grisham, No. 20-2176 (10th Cir. Nov. 15, 2022).unpublished
- D.T. v. Cherry Creek Sch., 55 F.4th 1268 (10th Cir. 2022).published
- Fisher v. Moore, 62 F.4th 912 (5th Cir. 2023).published
- Fisher v. Moore, 73 F.4th 367 (5th Cir. 2023).published
- Doe v. Brighton 27J Sch. Dist., No. 1:20-cv-00088 (D. Colo. Sept. 6, 2022).
- S.S. v. Cobb Cnty. Sch. Dist., No. 1:18-cv-00313 (N.D. Ga. Mar. 1, 2021).
- Indep. Sch. Dist. No. 283 v. E.M.D.H, No. 0:18-cv-00935 (D. Minn. Jan. 15, 2019).
- V.D. v. State Of New York, No. 2:19-cv-04306 (E.D.N.Y. Aug. 19, 2019).
- K.B. v. Katonah Lewisboro Union Free Sch. Dist., No. 7:18-cv-09553 (S.D.N.Y. Oct. 28, 2019).
- Fragnito v. Bd. of Educ. of the Suffern Cent. Sch. Dist., No. 7:19-cv-01598 (S.D.N.Y. July 21, 2020).
- Bd. of Educ. of the Mamaroneck Union Free Sch. Dist. v. D.B., No. 7:21-cv-07596 (S.D.N.Y. Mar. 31, 2024).
- L. v. Radnor Twp. Sch. Dist., No. 2:21-cv-01319 (E.D. Pa. Oct. 27, 2021).
- Cent. Bucks Sch. Dist. v. Q.M., No. 2:22-cv-01128 (E.D. Pa. Sept. 12, 2022).
- J.C. v. Upper Darby Sch. Dist., No. 2:20-cv-05030, 2022 WL 17324587 (E.D. Pa. Nov. 29, 2022).
- Wishard v. Waynesboro Area Sch. Dist., No. 1:18-cv-01665 (M.D. Pa. Aug. 21, 2020).
- Perez v. Weslaco Indep. Sch. Dist., No. 7:21-cv-00352 (S.D. Tex. Aug. 24, 2022).
- Cowan, No. 4:25-cv-00052 (D. Mont. Sept. 2, 2026).
- Rachel H. v. Dep't of Educ., 868 F.3d 1085 (9th Cir. 2017).published
- T.B. v. Prince George's Cnty. Bd. of Educ., 897 F.3d 566 (4th Cir. 2018).published
- J.S. v. Dist. of Columbia, No. 2021-0293 (D.D.C. Mar. 22, 2022).published
- H.R. v. Dist. of Columbia, No. 2021-1856 (D.D.C. Mar. 29, 2024).published
- K.I. v. Durham Pub. Schs. Bd. of Educ., No. 1:19-cv-00857, 2020 WL 3512213 (M.D.N.C. June 29, 2020).
137 S. Ct. at 1000 Defining the standard for free appropriate education51 citing cases[F]or most children, a FAPE will involve integration in the regular classroom[.]
- Maggie J. v. Donegal Sch. Dist., No. 5:20-cv-02782 (E.D. Pa. June 30, 2021). (the procedures are there for a reason, and their focus provides insight into what it means, for purposes of the FAPE definition, to ‘meet the unique needs’ of a child with a disability)
- Uhlenkamp v. Dist. of Columbia, No. 2021-2662 (D.D.C. Aug. 8, 2025).published ([F]or most children, a FAPE will involve integration in the regular classroom[.])
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. July 30, 2025).published ([F]or most children, a FAPE will involve integration in the regular classroom[.])
- N. T. v. Dist. of Columbia, No. 2023-0370 (D.D.C. July 9, 2025).published ([F]or most children, a FAPE will involve integration in the regular classroom[.])
- Irvine Unified Sch. Dist. v. Sharon Landers, No. 21-55290 (9th Cir. Dec. 26, 2023).unpublished “[A] FAPE will involve integration in the regular classroom and individualized special education calculated to achieve advancement from grade to grade.”
- Osseo Area Schs. v. A.J.T., No. 0:21-cv-01453 (D. Minn. Sept. 13, 2022). No. 623, 31 IDELR ¶ 17; Endrew F., 137 S. Ct. at 999 (“A focus on the particular child is at the core of the IDEA.”).
- C. K. v. Bd. of Educ. of Sylvania City Sch. Dist., No. 21-3244 (6th Cir. Sept. 9, 2022).unpublished Applying Endrew F., the district court correctly rejected this order and the legal analysis that supported it. 137 S. Ct. at 989 (“[T]he statement that the Act did not ‘guarantee any particular level of education’ simply reflects the unobj…
- R.S. v. Smith, No. 8:20-cv-01300, 2021 WL 3633961 (D. Md. Aug. 17, 2021). When a school identifies a student with special needs, it must prepare and implement an individualized educational plan (“IEP”) that is “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumsta…
- K. v. Sylvania City Schs., No. 3:19-cv-02753 (N.D. Ohio Feb. 9, 2021). Endrew F., 137 S. Ct. at 1002 (“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 progr…
- E. by R. Next Friend E. R. v. Spring Branch Indep. Sch. Dist., 909 F.3d 754 (5th Cir. 2018).published (standard [established in Endrew F. ] is markedly more demanding than the 'merely more than de minimis ' test applied by the Tenth Circuit)
Show 41 more citing cases
- Smith v. Dist. of Columbia, No. 2016-1386 (D.D.C. Sept. 28, 2018).published In Endrew F. v. Douglas County School District RE-1, the Court held that an IEP must be “reasonably calculated to enable [the] child to make progress appropriate in light of the child’s circumstances.” 137 S. Ct. at 999; see id. at 1001 (“…
- Killoran v. Westhampton Beach UFSD, No. 21-2647, 2023 WL 4503151 (2d Cir. July 13, 2023).unpublished “if progressing smoothly through the regular curriculum is not a reasonable prospect for 14 a child, his iep need not aim for grade-level advancement.”
- B. v. Smith, No. 8:18-cv-01780 (D. Md. July 9, 2019). Dist. RE-1, 137 S. Ct. 988 , 999 (2017) (“Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal.”).
- Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE-1, 694 F. App'x 654 (10th Cir. 2017).unpublished
- Z. B. v. D.C., No. 16-7113 (D.C. Cir. May 1, 2018).published
- Middleton v. Dist. of Columbia, No. 2017-0088 (D.D.C. June 4, 2018).published
- L. H. v. Hamilton Cty. Dep't of Educ., 900 F.3d 779 (6th Cir. 2018).published
- F.L. v. Bd. of Educ. of the, No. 17-2881 (2d Cir. Aug. 24, 2018).unpublished
- C.D. v. Natick Pub. Sch. Dist., 924 F.3d 621 (1st Cir. 2019).published
- R. S. v. Highland Park Indep Sch Dist, 951 F.3d 319 (5th Cir. 2020).published
- A.T. v. Dist. of Columbia, No. 2016-1086 (D.D.C. May 18, 2021).published
- D.C. v. Klein Indep Sch Dist, No. 20-20339 (5th Cir. June 17, 2021).unpublished
- H.W. v. Comal Indep Sch Dist, 32 F.4th 454 (5th Cir. 2022).published
- Brandywine Heights Area Sch. Dist. v. B.M. ex rel. B.M., 248 F. Supp. 3d 618 (E.D. Pa. 2017).published
- Endrew F. v. Douglas Cnty. Sch. Dist. Re 1, 290 F. Supp. 3d 1175 (D. Colo. 2018).published
- D. R. v. Rbusd, No. 21-56053 (9th Cir. Dec. 20, 2022).published
- Pierre-Noel v. Bridges Pub. Charter Sch., No. 2023-0070 (D.D.C. Apr. 6, 2023).published
- Banwart v. Cedar Falls Cmty. Sch. Dist., 489 F. Supp. 3d 846 (N.D. Iowa 2020).published
- Dragon v. Swampscott Pub. Schs., No. 1:19-cv-10431 (D. Mass. June 23, 2020).
- Whitaker v. Bd. of Educ. for Prince George's Cnty. Pub. Schs., No. 8:19-cv-02488 (D. Md. Aug. 25, 2020).
- Morrison v. Perry Sch. Dep't, No. 1:18-cv-00106 (D. Me. July 11, 2019).
- Mr & Mrs Catling v. York Sch. Dep't, No. 2:19-cv-00110 (D. Me. Oct. 28, 2020).
- Falmouth Sch. Dep't v. Mr & Mrs Doe, No. 2:20-cv-00214 (D. Me. Sept. 29, 2021).
- East Brunswick Twp. Bd. of Educ. v. D.S., No. 2:21-cv-08279 (D.N.J. July 28, 2023).unpublished
- Killoran v. Westhampton Beach UFSD, No. 2:19-cv-03298 (E.D.N.Y. Oct. 11, 2021).
- AR & KR v. Katonah Lewisboro Union Free Sch. Dist., No. 7:18-cv-09938 (S.D.N.Y. Nov. 21, 2019).
- J.N. v. Oregon Dep't of Educ., No. 6:19-cv-00096 (D. Or. Feb. 5, 2021).
- Perkiomen Valley Sch. Dist. v. S.D., No. 2:18-cv-02093 (E.D. Pa. Sept. 24, 2019).
- Perkiomen Valley Sch. Dist. v. R.B., 533 F. Supp. 3d 233 (E.D. Pa. 2021).published
- Moynihan v. West Chester Area Sch. Dist., No. 2:19-cv-00648 (E.D. Pa. Mar. 18, 2022).
- Matthew B. v. Pleasant Valley Sch. Dist., No. 3:17-cv-02380, 2019 WL 5692538 (M.D. Pa. Nov. 1, 2019).
- Irish J v. East Stroudsburg Area Sch. Dist., No. 3:19-cv-01926 (M.D. Pa. Aug. 6, 2020).
- Abigail, P. v. Old Forge Sch. Dist., No. 3:21-cv-02033 (M.D. Pa. Mar. 14, 2023).
- Lamar Consol. Indep. Sch. Dist. v. T., No. 4:20-cv-02353 (S.D. Tex. Dec. 31, 2021).
- William V. v. Copperas Cove Indep. Sch. Dist., No. 6:17-cv-00201 (W.D. Tex. Oct. 22, 2019).
- Amanda P. & Casey P. v. Copperas Cove Indep. Sch. Dist., No. 6:19-cv-00197 (W.D. Tex. Apr. 14, 2020).
- Grafton Sch. Dist. v. L, No. 2:19-cv-01179 (E.D. Wis. July 8, 2020).
- Edward M.R. v. D.C., 128 F.4th 290 (D.C. Cir. 2025).published
- L.B. v. Roselle Bd. of Educ., No. 2:18-cv-11588 (D.N.J. June 30, 2025).
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. May 5, 2026).published
- W.L., No. 4:25-cv-00003 (E.D. Tex. Sept. 24, 2026).
580 U.S. at 391 Evaluating the substantive standard of free appropriate public education33 citing casesThe IDEA requires that every IEP… set out ‘measurable annual goals, including academic and functional goals,’ along with a ‘description of how the child's progress toward meeting’ those goals will be gauged.
- Uhlenkamp v. Dist. of Columbia, No. 2021-2662 (D.D.C. Aug. 8, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. July 30, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. T. v. Dist. of Columbia, No. 2023-0370 (D.D.C. July 9, 2025).published Stated simply, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE wi…
- Philpot v. Dist. of Columbia, No. 2023-0671 (D.D.C. May 6, 2025).published Putting these principles together, then, “[t]he key inquiry regarding an IEP’s substantive adequacy is whether, taking account of what the school knew or reasonably should have known of a student’s needs at the time, the IEP it offered was…
- W. v. Upper Darby Sch. Dist., No. 2:22-cv-04347 (E.D. Pa. July 27, 2023). (The IDEA requires that every IEP… set out ‘measurable annual goals, including academic and functional goals,’ along with a ‘description of how the child's progress toward meeting’ those goals will be gauged.)
- Upper Darby Sch. Dist. v. K.W., No. 2:22-cv-04343 (E.D. Pa. July 27, 2023). (The IDEA requires that every IEP… set out ‘measurable annual goals, including academic and functional goals,’ along with a ‘description of how the child's progress toward meeting’ those goals will be gauged.)
- Student, No. 3:25-cv-02066 (D. Or. Aug. 12, 2026). Dist. RE-1, 580 U.S. 386 , 390 (2017) (“In exchange for the funds, a State pledges to comply with a number of statutory conditions.
- Mason G. v. W. Wayne Sch. Dist., No. 3:22-cv-00004 (M.D. Pa. Sept. 6, 2024).
- Dervishi v. Stamford Bd. of Educ., No. 3:21-cv-01184 (D. Conn. Mar. 30, 2023).
- Lab'y CHARTER Sch. v. MRS, No. 2:21-cv-05538 (E.D. Pa. May 27, 2025).
Show 23 more citing cases
- J. R. v. Ventura Unified Sch. Dist., 173 F.4th 1039 (9th Cir. 2026).published
- K.I. v. Durham Pub. Schs. Bd., 54 F.4th 779 (4th Cir. 2022).published
- Hind Bouabid v. Charlotte-Mecklenburg Schs. Bd. of Educ., 62 F.4th 851 (4th Cir. 2023).published
- W. v. Poudre Sch. Dist. R-1, 94 F.4th 1176 (10th Cir. 2024).published
- Osseo Area Schs., ISD 279 v. A.J.T., 96 F.4th 1062 (8th Cir. 2024).published
- Pitta v. Medeiros, No. 1:22-cv-11641, 2023 WL 3572391 (D. Mass. May 19, 2023).
- Abigail P. v. Old Forge Sch. Dist., 105 F.4th 57 (3d Cir. 2024).published
- J.H. v. New York City Dep't of Educ., No. 1:23-cv-04753 (S.D.N.Y. May 21, 2024).
- M. v. Upper Darby Sch. Dist., No. 2:21-cv-02941 (E.D. Pa. Sept. 27, 2023).
- John Halvorsen v. Powhatan Cnty. Sch. Bd., No. 1039232 (Va. Ct. App. July 23, 2024).unpublished
- E.C.D v. San Diego Unified Sch. Dist., No. 3:23-cv-00303 (S.D. Cal. Jan. 24, 2025).
- M.G. v. Rye City Sch. Dist., No. 7:23-cv-09742 (S.D.N.Y. Jan. 30, 2025).
- M.S. v. McKnight, No. 8:23-cv-02727 (D. Md. Mar. 20, 2025).
- J.T. v. Dist. of Columbia, No. 2024-1400 (D.D.C. July 21, 2025).published
- Spurwink Servs. Inc v. Doe, No. 2:25-cv-00026 (D. Me. Aug. 19, 2025).
- Soto v. of Puerto Rico, No. 3:24-cv-01405 (D.P.R. Sept. 30, 2025).
- Jacobs v. Salt Lake City Sch. Dist., 154 F.4th 790 (10th Cir. 2025).published
- Aloy, No. 3:24-cv-01653 (S.D. Cal. Oct. 22, 2025).
- James F. v. Clear Creek Indep. Sch. Dist., No. 4:23-cv-02063 (S.D. Tex. Mar. 3, 2026).
- C.E., No. 8:24-cv-01941 (D. Md. Mar. 26, 2026).
- A.A., No. 2:25-cv-01377 (W.D. Wash. July 6, 2026).
- Singh, No. 2:24-cv-02511 (E.D. Cal. June 22, 2026).
- Cordova, No. 1:25-cv-03572 (S.D.N.Y. Sept. 28, 2026).
580 U.S. at 390 Determining if IEP is reasonably calculated to provide benefit27 citing cases
- M.S. v. Downingtown Area Sch. Dist., No. 2:20-cv-05085 (E.D. Pa. Oct. 28, 2022). A “reasonably calculated” IEP “requires a prospective judgment by school officials.” Id. at 399 (“The IEP must aim to enable the child to make progress” and “progress contemplated by the IEP”).
- Hilyer v. Elmore Cnty. Bd. of Educ., No. 2:22-cv-00705 (M.D. Ala. Feb. 16, 2024).
- Dervishi v. Stamford Bd. of Educ., No. 3:21-cv-01184 (D. Conn. Mar. 30, 2023).
- G. v. Brandywine Sch. Dist., No. 1:22-cv-00152 (D. Del. Mar. 21, 2023).
- J.E. v. Bd. of Educ. of the City of Chicago, No. 1:23-cv-02274 (N.D. Ill. Mar. 28, 2024).
- S.B. v. Bureau of Special Educ. Appeals, No. 1:22-cv-10056 (D. Mass. Mar. 28, 2024).
- F.V. & M.V. v. Cherry Hill Twp. Bd. of Educ., No. 1:21-cv-18096, 2023 WL 2662697 (D.N.J. Mar. 28, 2023).
- J. v. Kennett Consol. Sch. Dist., No. 2:21-cv-04495 (E.D. Pa. Feb. 1, 2023).
- F. v. Upper Darby Sch. Dist., No. 2:21-cv-05653 (E.D. Pa. Apr. 6, 2023).
- Hempfield Sch. Dist. v. S.C., No. 5:23-cv-02800 (E.D. Pa. Jan. 31, 2024).
Show 17 more citing cases
- LE v. Methacton Sch. Dist., No. 2:20-cv-02096 (E.D. Pa. Apr. 25, 2024).
- ABL v. Providence Pub. Schs., No. 1:22-cv-00379 (D.R.I. Nov. 3, 2023).
- G.T. v. Bd. of Educ. of the Cnty. of Kanawha, 117 F.4th 193 (4th Cir. 2024).published
- I.S. v. Fulton Cnty. Sch. Dist., No. 23-13456 (11th Cir. Oct. 31, 2024).unpublished
- S.M. v. Mcknight, No. 8:23-cv-01387 (D. Md. Sept. 30, 2024).
- Mantua Twp. Bd. of Educ. v. E.K., No. 1:22-cv-07496 (D.N.J. Sept. 30, 2023).
- W. v. West Chester Area Sch. Dist., No. 2:23-cv-01306 (E.D. Pa. Sept. 26, 2024).
- S.M. v. Chichester Sch. Dist., No. 2:21-cv-04266 (E.D. Pa. Oct. 7, 2024).
- Jacobs v. Salt Lake City Sch. Dist., No. 2:21-cv-00706 (D. Utah Mar. 31, 2023).
- Moonsammy v. Banks, No. 1:23-cv-10491 (S.D.N.Y. Mar. 7, 2025).
- Lab'y CHARTER Sch. v. MRS, No. 2:21-cv-05538 (E.D. Pa. May 27, 2025).
- Otero v. Aviles-Ramos, No. 1:25-cv-02773 (S.D.N.Y. July 24, 2025).
- C.P. v. Seattle Pub. Schs., No. 2:25-cv-00286 (W.D. Wash. Sept. 22, 2025).
- Bd. of Educ. for the Gallup-McKinley Cnty. Schs. v. Steinhaus, No. A-1-CA-41107 (N.M. Ct. App. Sept. 4, 2025).unpublished
- North East Indep Sch Dist v. M., No. 24-50833 (5th Cir. Dec. 23, 2025).published
- T.L. Individually & A/N/F of J.T. v. New Caney Indep. Sch. Dist., No. 4:24-cv-01435 (S.D. Tex. Feb. 26, 2026).
- J. R. v. Ventura Unified Sch. Dist., 173 F.4th 1039 (9th Cir. 2026).published
137 S. Ct. at 993 Requiring free appropriate public education under IDEA22 citing casesIn exchange for the funds, a State pledges to comply with a number of statutory conditions. Among them, the State must provide a free appropriate public education—a FAPE, for short—to all eligible children.
- Stevens Senior v. Ritenior Sch. Dist., No. 4:22-cv-01181 (E.D. Mo. May 24, 2023). Cf Fry, 137 S. Ct. at 755 (“[T]he only relief the IDEA makes available is relief for the denial of a FAPE.”).
- Osseo Area Schs. v. A.J.T., No. 0:21-cv-01453 (D. Minn. Sept. 13, 2022). No. 623, 31 IDELR ¶ 17; Endrew F., 137 S. Ct. at 999 (“A focus on the particular child is at the core of the IDEA.”).
- Hood River Cnty. Sch. Dist. v. Student, No. 3:20-cv-01690 (D. Or. July 1, 2021). (In exchange for the funds, a State pledges to comply with a number of statutory conditions. Among them, the State must provide a free appropriate public education—a FAPE, for short—to all eligible children.)
- K. v. Sylvania City Schs., No. 3:19-cv-02753 (N.D. Ohio Feb. 9, 2021). Endrew F., 137 S. Ct. at 1002 (“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 progr…
- D.C. v. Klein Indep Sch Dist, No. 20-20339 (5th Cir. June 17, 2021).unpublished
- Moynihan v. West Chester Area Sch. Dist., No. 2:19-cv-00648 (E.D. Pa. Mar. 18, 2022).
- W. v. Poudre Sch. Dist. R-1, No. 1:19-cv-01270 (D. Colo. July 15, 2022).
- B.M. v. Pleasantville Union Free Sch. Dist., No. 7:20-cv-02192-KMK, 2021 WL 4392281 (S.D.N.Y. Sept. 24, 2021).
- D.L. v. Dist. of Columbia, 860 F.3d 713 (D.C. Cir. 2017).published
- Miguel Luna Perez v. Sturgis Pub. Schs., 3 F.4th 236 (6th Cir. 2021).published
Show 12 more citing cases
- T.R. v. Sch. Dist. of Philadelphi, 4 F.4th 179 (3d Cir. 2021).published
- D.o. v. Jackson Twp. Bd. of Educ., No. A-3783-19 (N.J. Super. Ct. App. Div. July 19, 2021).unpublished
- Matter of Elmira City Sch. Dist. v. New York State Educ. Dept., 204 A.D.3d 1134 (N.Y. App. Div. 3d Dep't 2022).published
- B. v. Houston Indep Sch Dist, No. 21-20229 (5th Cir. Sept. 19, 2022).unpublished
- W.S. v. Dallas Indep Sch Dist, No. 21-10849 (5th Cir. Oct. 7, 2022).unpublished
- Caldara v. Boulder Valley Sch. Dist. RE-2, No. 1:22-cv-00564 (D. Colo. Dec. 21, 2023).
- A.C. v. Brandywine Sch. Dist., No. 1:21-cv-00713 (D. Del. Feb. 10, 2023).
- F. v. Bd. of Educ. of Chicago Pub. Sch. Dist. 299, No. 1:22-cv-02608 (N.D. Ill. June 2, 2022).
- Q.C. v. Winston-salem/forsyth Cnty. Schs. Bd. of Educ., No. 1:19-cv-01152 (M.D.N.C. May 26, 2022).
- Loper v. Cleveland Metro. Sch. Dist., No. 1:22-cv-01262 (N.D. Ohio Oct. 11, 2022).
- Zamora v. Hays Consol. Indep. Sch. Dist., No. 1:19-cv-01087 (W.D. Tex. June 20, 2021).
- Daniels v. Northshore Sch. Dist., No. 2:20-cv-01041 (W.D. Wash. Aug. 25, 2021).
580 U.S. at 403 Determining the standard for appropriate educational progress21 citing casesWe 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 [Plan] turns on the unique circumstances of the child for whom it was created
- Am, No. 2:25-cv-02524 (E.D. Pa. Jan. 23, 2026). (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 [Plan] turns…)
- Uhlenkamp v. Dist. of Columbia, No. 2021-2662 (D.D.C. Aug. 8, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. July 30, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. T. v. Dist. of Columbia, No. 2023-0370 (D.D.C. July 9, 2025).published Stated simply, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE wi…
- Moore-Watson v. Rankin Cty Pub Sch, No. 22-60067 (5th Cir. May 2, 2025).unpublished Susquehanna Intermediate Unit 16, 853 F.2d 171 , 182 (3d Cir. 1988)). 8 Endrew F., 580 U.S. at 403; see also id. at 402-03 (“When all is said and done, a student offered an educational program providing ‘merely more than de minimis’ progre…
- Doe v. Vineland City Bd. of Educ., No. 1:19-cv-12154 (D.N.J. Jan. 17, 2024). Though Plaintiffs assert that this standard is incorrect, the Court finds that it closely tracks the language of Endrew F. that “[t]he IDEA . . . . requires an educational program reasonably calculated to enable a child to make progress ap…
- L.B. v. Roselle Bd. of Educ., No. 2:18-cv-11588 (D.N.J. June 30, 2025).
- R.F., No. 1:24-cv-03117 (S.D.N.Y. Sept. 22, 2025).
- Lausd v. A. O., No. 22-55204 (9th Cir. Feb. 15, 2024).published
- J.M. v. Genesee Intermediate Sch. Dist., No. 2:23-cv-12896 (E.D. Mich. Sept. 30, 2025).
Show 11 more citing cases
- Does v. Pulaski Cnty. Special Sch. Dist., No. 4:23-cv-01039 (E.D. Ark. Sept. 10, 2025).
- C.B. v. Henry Cnty. Sch. Dist., 167 F.4th 1134 (11th Cir. 2026).published
- Charles Kass v. W. Dubuque Comm. Sch. Dist., 101 F.4th 562 (8th Cir. 2024).published
- J.T. v. Denver Pub. Schs., No. 1:21-cv-01227 (D. Colo. Jan. 30, 2023).
- S.K. v. Bernards Twp. Bd. of Educ., No. 3:23-cv-01279 (D.N.J. Feb. 29, 2024).unpublished
- D.M. v. Watchung Hills Reg'l High Sch. Bd. of Educ., No. 3:22-cv-07500 (D.N.J. Mar. 5, 2024).unpublished
- C. v. Pennsbury Sch. Dist., No. 2:22-cv-04080 (E.D. Pa. Aug. 18, 2023).
- P. v. McKnight, No. 8:23-cv-01680 (D. Md. July 29, 2024).
- H.R. v. West Windsor-plainsboro Bd. of Educ., No. 3:22-cv-03103 (D.N.J. July 25, 2023).unpublished
- Robertson v. Dist. of Columbia, No. 2024-0656 (D.D.C. Jan. 16, 2026).published
- C.F., No. 2:24-cv-00402 (E.D. Pa. June 22, 2026).
580 U.S. at 404 Reviewing court's role in IEP adequacy determination21 citing casesThe adequacy of a given IEP turns on the unique circumstances of the child for whom it was created.
- M.R. v. Dist. of Columbia, No. 2025-0556 (D.D.C. July 15, 2026).published A court reviewing an administrative IDEA determination “shall grant such relief as the court determines is appropriate,” based upon “a preponderance of the evidence.” 20 U.S.C. § 1415 (i)(2)(C)(iii); see also Rowley, 458 U.S. at 205-206. 1…
- N. v. Dist. of Columbia, No. 2024-0109 (D.D.C. July 30, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- N. T. v. Dist. of Columbia, No. 2023-0370 (D.D.C. July 9, 2025).published Stated simply, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE wi…
- S.M. v. Freehold Reg'l High Sch. Dist. Bd. of Educ., No. 3:22-cv-00107 (D.N.J. Jan. 17, 2024).(The adequacy of a given IEP turns on the unique circumstances of the child for whom it was created.)
- M.S. v. Downingtown Area Sch. Dist., No. 2:20-cv-05085 (E.D. Pa. Oct. 28, 2022). A “reasonably calculated” IEP “requires a prospective judgment by school officials.” Id. at 399 (“The IEP must aim to enable the child to make progress” and “progress contemplated by the IEP”).
- L.B. v. Roselle Bd. of Educ., No. 2:18-cv-11588 (D.N.J. June 30, 2025).
- Mason G. v. W. Wayne Sch. Dist., No. 3:22-cv-00004 (M.D. Pa. Sept. 6, 2024).
- Cockrell v. Bessemer City Bd. of Educ., No. 2:22-cv-01494 (N.D. Ala. Sept. 27, 2024).
- AA v. Montgomery Cnty. Pub. Schs., No. 8:24-cv-01675 (D. Md. Sept. 12, 2025).
- C.B. v. Henry Cnty. Sch. Dist., 167 F.4th 1134 (11th Cir. 2026).published
Show 11 more citing cases
- J.T. v. Denver Pub. Schs., No. 1:21-cv-01227 (D. Colo. Jan. 30, 2023).
- C. v. Pennsbury Sch. Dist., No. 2:22-cv-04080 (E.D. Pa. Aug. 18, 2023).
- Zachary J. v. Colonial Sch. Dist., No. 22-1509, 2024 U.S. App. LEXIS 2187 (3d Cir. Jan. 31, 2024).unpublished
- A.D. & M.D. v. Upper Merion Area Sch. Dist., No. 2:21-cv-05468, 2022 WL 16553379 (E.D. Pa. Oct. 28, 2022).
- Derrick v. Glen Mills Schs., No. 2:19-cv-01541, 2024 WL 2134340 (E.D. Pa. May 13, 2024).
- H.R. v. Dist. of Columbia, No. 2021-1856 (D.D.C. July 30, 2024).published
- George v. Davis Sch. Dist., No. 2:23-cv-00139 (D. Utah Aug. 4, 2023).
- N.K.M. v. Rye City Sch. Dist., No. 7:23-cv-01109 (S.D.N.Y. Nov. 15, 2024).
- Cruz v. Banks, 134 F.4th 687 (2d Cir. 2025).published
- J-D. v. Dist. of Columbia, No. 2024-0707 (D.D.C. Sept. 22, 2025).published
- W.H. v. Fort Bend ISD, No. 25-20361 (5th Cir. Sept. 8, 2026).unpublished
580 U.S. at 402 Determining the required level of educational progress for students18 citing casesWhen 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. . . . The IDEA demands more.
- Uhlenkamp v. Dist. of Columbia, No. 2021-2662 (D.D.C. Aug. 8, 2025).published More simply put, “the IDEA requires that children with disabilities receive education in the regular classroom whenever possible.” Endrew F., 580 U.S. at 400 (citation and quotation marks omitted); id. at 401 (“[F]or most children, a FAPE…
- Moore-Watson v. Rankin Cty Pub Sch, No. 22-60067 (5th Cir. May 2, 2025).unpublished (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. . . . The IDEA demands…)
- East Brunswick Twp. Bd. of Educ. v. D.S., No. 2:21-cv-08279 (D.N.J. July 28, 2023).unpublished
- L.B. v. Roselle Bd. of Educ., No. 2:18-cv-11588 (D.N.J. June 30, 2025).
- H.L. v. Tri-Valley Sch. Dist., No. 3:20-cv-01125 (M.D. Pa. Mar. 14, 2023).
- Mason G. v. W. Wayne Sch. Dist., No. 3:22-cv-00004 (M.D. Pa. Sept. 6, 2024).
- R.F., No. 1:24-cv-03117 (S.D.N.Y. Sept. 22, 2025).
- Lausd v. A. O., No. 22-55204 (9th Cir. Feb. 15, 2024).published
- J.M. v. Genesee Intermediate Sch. Dist., No. 2:23-cv-12896 (E.D. Mich. Sept. 30, 2025).
- Phillips v. Banks, No. 23-362, 2024 WL 1208954 (2d Cir. Mar. 21, 2024).unpublished
Show 8 more citing cases
- R.S. & R.S. v. Lower Merion Sch. Dist., 660 F. Supp. 3d 284 (E.D. Pa. 2023).published
- A. v. Clarksville-Montgomery Cnty. Schs., No. 3:23-cv-00912 (M.D. Tenn. May 24, 2024).
- Does v. Pulaski Cnty. Special Sch. Dist., No. 4:23-cv-01039 (E.D. Ark. Sept. 10, 2025).
- AA v. Montgomery Cnty. Pub. Schs., No. 8:24-cv-01675 (D. Md. Sept. 12, 2025).
- C.B. v. Henry Cnty. Sch. Dist., 167 F.4th 1134 (11th Cir. 2026).published
- E.W., No. 5:25-cv-02904 (E.D. Pa. Feb. 17, 2026).
- A.O.B. v. Departamento De Educación, No. TA2026RA00146 (June 29, 2026).published
- E.S., No. 8:25-cv-00484 (C.D. Cal. July 28, 2026).
137 S. Ct. at 998 Defining the scope of educational benefit under the IDEA16 citing casesnoting that Rowley "involved a child whose progress plainly demonstrated that her IEP was designed to deliver more than adequate educational benefits
- R.S. v. Smith, No. 8:20-cv-01300, 2021 WL 3633961 (D. Md. Aug. 17, 2021). When a school identifies a student with special needs, it must prepare and implement an individualized educational plan (“IEP”) that is “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumsta…
- K. v. Sylvania City Schs., No. 3:19-cv-02753 (N.D. Ohio Feb. 9, 2021). Endrew F., 137 S. Ct. at 1002 (“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 progr…
- Edward M.R. v. D.C., 128 F.4th 290 (D.C. Cir. 2025).published
- L.J. v. Sch. Bd. of Broward Cnty., 927 F.3d 1203 (11th Cir. 2019).published
- Enter. City Bd. of Educ. v. S.S., No. 1:19-cv-00748 (M.D. Ala. June 12, 2020).
- O.P. v. Jefferson Cnty. Bd. of Educ., No. 2:22-cv-00030 (N.D. Ala. Feb. 7, 2023).
- Bd. Of Educ. Of Montgomery Cnty. v. S.M., No. 8:20-cv-02301 (D. Md. Mar. 30, 2022).
- D.C. v. Klein Indep. Sch. Dist., No. 4:19-cv-00021 (S.D. Tex. May 29, 2020).
- I.Z.M. v. Rosemount-Apple Valley-Eagan Pub. Schs., 863 F.3d 966 (8th Cir. 2017).published
- United States v. Eddy Wilmer Vail-Bailon, 868 F.3d 1293 (11th Cir. 2017).published
Show 4 more citing cases
- Somberg ex rel. Somberg v. Utica Cmty. Sch., 908 F.3d 162 (6th Cir. 2018).published
- Elizabeth B. v. El Paso Cnty. Sch. Dist., No. 19-1299 (10th Cir. Dec. 16, 2020).unpublished
- P v. Parkland Sch. Dist., No. 5:20-cv-04447 (E.D. Pa. Aug. 25, 2021).
- C.B. v. Nazareth Area Sch. Dist. Sch. Dist., No. 5:24-cv-00844 (E.D. Pa. Jan. 6, 2025).
137 S. Ct. at 1002 Expectation of cogent explanation for IEP's reasonableness12 citing casesA 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.
- K. v. Sylvania City Schs., No. 3:19-cv-02753 (N.D. Ohio Feb. 9, 2021). (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 appropr…)
- Smith v. Dist. of Columbia, No. 2016-1386 (D.D.C. Sept. 28, 2018).published In Endrew F. v. Douglas County School District RE-1, the Court held that an IEP must be “reasonably calculated to enable [the] child to make progress appropriate in light of the child’s circumstances.” 137 S. Ct. at 999; see id. at 1001 (“…
- Davis v. Dist. of Columbia, 244 F. Supp. 3d 27 (D.D.C. 2017).published “a reviewing, court may fairly expect those authorities to be able to. offer a cogent and responsive explanation for their decisions.”
- AR & KR v. Katonah Lewisboro Union Free Sch. Dist., No. 7:18-cv-09938 (S.D.N.Y. Nov. 21, 2019).
- Perkiomen Valley Sch. Dist. v. R.B., 533 F. Supp. 3d 233 (E.D. Pa. 2021).published
- Bd. Of Educ. Of Montgomery Cnty. v. S.M., No. 8:20-cv-02301 (D. Md. Mar. 30, 2022).
- B. v. Smith, No. 8:21-cv-00781 (D. Md. May 26, 2022).
- J. W. v. Medford Lakes Bd. of Educ., No. 1:19-cv-20589 (D.N.J. Aug. 18, 2021).
- R.B. v. Dist. of Columbia, No. 2018-0662 (D.D.C. Sept. 30, 2019).published
- Nathan M. v. Harrison Sch. Dist. No. 2, 942 F.3d 1034 (10th Cir. 2019).published
Show 2 more citing cases
- O. v. Glastonbury Bd. of Educ., No. 3:20-cv-00690 (D. Conn. Dec. 29, 2021).
- Colonial Sch. Dist. v. E.G., No. 2:19-cv-01173 (E.D. Pa. Jan. 31, 2020).
137 S. Ct. at 996 Defining the required progress of an individualized education program9 citing cases“a child has received a fape if the child's iep sets out an educational program that is 'reasonably calculated to enable the child to receive educational benefits.”
- Maggie J. v. Donegal Sch. Dist., No. 5:20-cv-02782 (E.D. Pa. June 30, 2021). Op. at 18; but see Endrew F., 137 S. Ct. at 1000 (“the procedures are there for a reason, and their focus provides insight into what it means, for purposes of the FAPE definition, to ‘meet the unique needs’ of a child with a disability”).…
- JA v. Royal Oak Sch. Dist., No. 4:23-cv-13106 (E.D. Mich. Sept. 4, 2025). “a child has received a fape if the child's iep sets out an educational program that is 'reasonably calculated to enable the child to receive educational benefits.”
- Dragon v. Swampscott Pub. Schs., No. 1:19-cv-10431 (D. Mass. June 23, 2020).
- AR & KR v. Katonah Lewisboro Union Free Sch. Dist., No. 7:18-cv-09938 (S.D.N.Y. Nov. 21, 2019).
- Abigail, P. v. Old Forge Sch. Dist., No. 3:21-cv-02033 (M.D. Pa. Mar. 14, 2023).
- Shaw v. Dist. of Columbia, No. 2017-0738 (D.D.C. Feb. 8, 2019).published
- B.M. v. Pleasantville Union Free Sch. Dist., No. 7:20-cv-02192-KMK, 2021 WL 4392281 (S.D.N.Y. Sept. 24, 2021).
- O. v. Sch. Dist. of Philadelphia, No. 2:20-cv-01991 (E.D. Pa. Dec. 29, 2021).
- Mr & Ms Doe v. Portland Pub. Schs., No. 2:20-cv-00461 (D. Me. July 14, 2022).
580 U.S. at 394 Defining the required level of educational progress8 citing cases
- M. v. Cent. Bucks Sch. Dist., No. 2:23-cv-03180 (E.D. Pa. Feb. 28, 2024). Dist. RE-1, 580 U.S. 386 , 391 (2017). 119 Id. at 394. 120 QM II, ECF No. 17-3 at 2. 121 QM I, ECF No. 10-3 at 29. 122 QM II, ECF No. 17-3 at 22. 123 Id. at 23. 124 QM I, ECF No. 10-3 at 18, 21-22. 125 Id. at 14. 126 QM II, ECF No. 17-3 at…
- Jacobs v. Salt Lake City Sch. Dist., No. 2:21-cv-00706 (D. Utah Mar. 31, 2023).
- M. v. Upper Darby Sch. Dist., No. 2:21-cv-02941 (E.D. Pa. Sept. 27, 2023).
- James F. v. Clear Creek Indep. Sch. Dist., No. 4:23-cv-02063 (S.D. Tex. Mar. 3, 2026).
- Cordova, No. 1:25-cv-03572 (S.D.N.Y. Sept. 28, 2026).
- Lausd v. A. O., No. 22-55204 (9th Cir. Feb. 15, 2024).published
- Cockrell v. Bessemer City Bd. of Educ., No. 2:22-cv-01494 (N.D. Ala. Sept. 27, 2024).
- BS v. Bd. of Educ. of Downers Grove Grade Sch. Dist. 58, No. 1:23-cv-16446 (N.D. Ill. May 28, 2025).
137 S. Ct. at 997 Rejecting the de minimis standard for educational benefit8 citing cases“educational benefit that is merely . . . more than de minimis.”
- R.F. v. Cecil Cnty. Pub. Schs., 919 F.3d 237 (4th Cir. 2019).published RE-1 , --- U.S. ----, 137 S.Ct. 988 , 994, 197 L.Ed.2d 335 (2017) ("The IEP is the centerpiece of the [IDEA's] education delivery system for disabled children.") (citation and internal quotation marks omitted).
- Brandywine Heights Area Sch. Dist. v. B.M. ex rel. B.M., 248 F. Supp. 3d 618 (E.D. Pa. 2017).published
- Dragon v. Swampscott Pub. Schs., No. 1:19-cv-10431 (D. Mass. June 23, 2020).
- Moynihan v. West Chester Area Sch. Dist., No. 2:19-cv-00648 (E.D. Pa. Mar. 18, 2022).
- J.B. v. Dist. of Columbia Pub. Schs., No. 2017-1298 (D.D.C. Sept. 6, 2018).published
- C. G. ex rel. Keith v. Waller Indep. Sch. Dist., 697 F. App'x 816 (5th Cir. 2017).unpublished
- J.B. v. Dist. of Columbia, 325 F. Supp. 3d 1 (D.C. Cir. 2018).published
137 S. Ct. at 992 Determining appropriate ambition for educational programming8 citing casesreiterating, "advancement from grade to grade is appropriately ambitious for most children in the regular classroom
- Middleton v. Dist. of Columbia, No. 2017-0088 (D.D.C. June 4, 2018).published
- A.T. v. Dist. of Columbia, No. 2016-1086 (D.D.C. May 18, 2021).published
- C. G. ex rel. Keith v. Waller Indep. Sch. Dist., 697 F. App'x 816 (5th Cir. 2017).unpublished
- P. P. v. Nw. Indep Sch. Dist, No. 20-10197 (5th Cir. Dec. 14, 2020).unpublished
- B.B. v. Dist. of Columbia, No. 2020-2467, 2022 WL 834146 (D.D.C. Mar. 21, 2022).published
- Jerry M. v. Riesel Indep. Sch. Dist., 379 F. Supp. 3d 570 (W.D. Tex. 2019).published
580 U.S. at 386 Defining free appropriate public education and IEP components4 citing casesAny review of an IEP must appreciate that the question is 22 whether the IEP is reasonable, not whether the court regards it as ideal.
- W. v. Peninsula Sch. Dist., No. 3:24-cv-05820 (W.D. Wash. June 5, 2025).(Any review of an IEP must appreciate that the question is 22 whether the IEP is reasonable, not whether the court regards it as ideal.)
- H.L. v. Tri-Valley Sch. Dist., No. 3:20-cv-01125 (M.D. Pa. Mar. 14, 2023).
- Mason G. v. W. Wayne Sch. Dist., No. 3:22-cv-00004 (M.D. Pa. Sept. 6, 2024).
- C., No. 2:24-cv-01623 (W.D. Pa. May 15, 2026).
580 U.S. at 398 Determining the standard for appropriate educational progress4 citing cases[T]he [Rowley court’s] statement that the [IDEA] did not ‘guarantee any particular level of education’ simply reflects the unobjectionable proposition that the IDEA cannot and does not promise ‘any particular [educational] outcome.’ No law could do that—for any child.” (last alteration in original…
- M.S. v. Downingtown Area Sch. Dist., No. 2:20-cv-05085 (E.D. Pa. Oct. 28, 2022). A “reasonably calculated” IEP “requires a prospective judgment by school officials.” Id. at 399 (“The IEP must aim to enable the child to make progress” and “progress contemplated by the IEP”).
- S. v. Downingtown Area Sch. Dist., No. 2:23-cv-03270 (E.D. Pa. June 10, 2024).
- William A. v. Clarksville-Montgomery Cnty. Sch. Sys., 127 F.4th 656 (6th Cir. 2025).published
- J.M. v. Genesee Intermediate Sch. Dist., No. 2:23-cv-12896 (E.D. Mich. Sept. 30, 2025).
580 U.S. at 388 Defining the substantive standard for free appropriate public education3 citing cases
- M.R. v. Dist. of Columbia, No. 2025-0556 (D.D.C. July 15, 2026).published A court reviewing an administrative IDEA determination “shall grant such relief as the court determines is appropriate,” based upon “a preponderance of the evidence.” 20 U.S.C. § 1415 (i)(2)(C)(iii); see also Rowley, 458 U.S. at 205-206. 1…
- G.L. v. Dist. of Columbia, No. 2024-0280 (D.D.C. Aug. 22, 2025).published
- R.F., No. 1:24-cv-03117 (S.D.N.Y. Sept. 22, 2025).
580 U.S. at 387 IEP goals need not aim for grade-level advancement2 citing casesA child’s IEP need not aim for grade-level advancement if that is not a reasonable prospect.
- Lee v. Prince George Cnty. Pub. Sch., No. 8:22-cv-00957 (D. Md. Jan. 31, 2024). (A child’s IEP need not aim for grade-level advancement if that is not a reasonable prospect.)
137 S. Ct. at 988 “in exchange for the funds, a state pledges to comply with a number of statutory conditions. among them, the state must provide a free appropriate public education-a fape, for short-to all eligible children.”1 citing case
- Student, No. 3:25-cv-02066 (D. Or. Aug. 12, 2026). “in exchange for the funds, a state pledges to comply with a number of statutory conditions. among them, the state must provide a free appropriate public education-a fape, for short-to all eligible children.”
137 S. Ct. at 989 IDEA does not guarantee specific educational outcomes1 citing case[T]he statement that the Act did not ‘guarantee any particular level of education’ simply reflects the unobjectionable proposition that the IDEA cannot and does not promise ‘any particular [educational] outcome.’
- C. K. v. Bd. of Educ. of Sylvania City Sch. Dist., No. 21-3244 (6th Cir. Sept. 9, 2022).unpublished ([T]he statement that the Act did not ‘guarantee any particular level of education’ simply reflects the unobjectionable proposition that the IDEA cannot and does not promise ‘any particular [educational] outcome.’)
Other citing cases
- S.M. v. Chichester Sch. Dist., No. 2:21-cv-04266 (E.D. Pa. Aug. 19, 2025).
- K.W. v. Dist. of Columbia, No. 2018-2578 (D.D.C. May 7, 2019).published
v.
DOUGLAS COUNTY SCHOOL DISTRICT RE-1.
Thirty-five years ago, this Court held that the Individuals with Disabilities Education Act establishes a substantive right to a "free appropriate public education" for certain children with disabilities. Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley, 458 U.S. 176, 102 S.Ct. 3034, 73 L.Ed.2d 690 (1982). We declined, however, to endorse any one standard for determining "when handicapped children are receiving sufficient educational benefits to satisfy the requirements of the Act." Id., at 202, 102 S.Ct. 3034. That "more difficult problem" is before us today. Ibid.
I
A
The Individuals with Disabilities Education Act (IDEA or Act) offers States federal funds to assist in educating children with disabilities. 84 Stat. 175, as amended, 20 U.S.C. § 1400 et seq. ; see Arlington Central School Dist. Bd. of Ed. v. Murphy, 548 U.S. 291, 295, 126 S.Ct. 2455, 165 L.Ed.2d 526 (2006). In exchange for the funds, a State pledges to comply with a number of statutory conditions. Among them, the State must provide a free appropriate public education-a FAPE, for short-to all eligible children. § 1412(a)(1).
[*994] A FAPE, as the Act defines it, includes both "special education" and "related services." § 1401(9). "Special education" is "specially designed instruction ... to meet the unique needs of a child with a disability"; "related services" are the support services "required to assist a child ... to benefit from" that instruction. §§ 1401(26), (29). A State covered by the IDEA must provide a disabled child with such special education and related services "in conformity with the [child's] individualized education program," or IEP. § 1401(9)(D).
The IEP is "the centerpiece of the statute's education delivery system for disabled children." Honig v. Doe, 484 U.S. 305, 311, 108 S.Ct. 592, 98 L.Ed.2d 686 (1988). A comprehensive plan prepared by a child's "IEP Team" (which includes teachers, school officials, and the child's parents), an IEP must be drafted in compliance with a detailed set of procedures. § 1414(d)(1)(B) (internal quotation marks omitted). These procedures emphasize collaboration among parents and educators and require careful consideration of the child's individual circumstances. § 1414. The IEP is the means by which special education and related services are "tailored to the unique needs" of a particular child. Rowley, 458 U.S., at 181, 102 S.Ct. 3034.
The IDEA requires that every IEP include "a statement of the child's present levels of academic achievement and functional performance," describe "how the child's disability affects the child's involvement and progress in the general education curriculum," and set out "measurable annual goals, including academic and functional goals," along with a "description of how the child's progress toward meeting" those goals will be gauged. §§ 1414(d)(1)(A)(i)(I)-(III). The IEP must also describe the "special education and related services ... that will be provided" so that the child may "advance appropriately toward attaining the annual goals" and, when possible, "be involved in and make progress in the general education curriculum." § 1414(d)(1)(A)(i)(IV).
Parents and educators often agree about what a child's IEP should contain. But not always. When disagreement arises, parents may turn to dispute resolution procedures established by the IDEA. The parties may resolve their differences informally, through a "[p]reliminary meeting," or, somewhat more formally, through mediation. §§ 1415(e), (f)(1)(B)(i). If these measures fail to produce accord, the parties may proceed to what the Act calls a "due process hearing" before a state or local educational agency. §§ 1415(f)(1)(A), (g). And at the conclusion of the administrative process, the losing party may seek redress in state or federal court. § 1415(i)(2)(A).
B
This Court first addressed the FAPE requirement in Rowley .[1] Plaintiff Amy Rowley was a first grader with impaired hearing. Her school district offered an IEP under which Amy would receive instruction in the regular classroom and spend time each week with a special tutor and a speech therapist. The district proposed that Amy's classroom teacher speak into a wireless transmitter and that Amy use an FM hearing aid designed to amplify her teacher's words; the district offered to[*995] supply both components of this system. But Amy's parents argued that the IEP should go further and provide a sign-language interpreter in all of her classes. Contending that the school district's refusal to furnish an interpreter denied Amy a FAPE, Amy's parents initiated administrative proceedings, then filed a lawsuit under the Act. Rowley, 458 U.S., at 184-185, 102 S.Ct. 3034.
The District Court agreed that Amy had been denied a FAPE. The court acknowledged that Amy was making excellent progress in school: She was "perform[ing] better than the average child in her class" and "advancing easily from grade to grade." Id., at 185, 102 S.Ct. 3034 (internal quotation marks omitted). At the same time, Amy "under[stood] considerably less of what goes on in class than she could if she were not deaf." Ibid. (internal quotation marks omitted). Concluding that "it has been left entirely to the courts and the hearings officers to give content to the requirement of an 'appropriate education,' " 483 F.Supp. 528, 533 (S.D.N.Y.1980), the District Court ruled that Amy's education was not "appropriate" unless it provided her "an opportunity to achieve [her] full potential commensurate with the opportunity provided to other children. " Rowley, 458 U.S., at 185-186, 102 S.Ct. 3034 (internal quotation marks omitted). The Second Circuit agreed with this analysis and affirmed.
In this Court, the parties advanced starkly different understandings of the FAPE requirement. Amy's parents defended the approach of the lower courts, arguing that the school district was required to provide instruction and services that would provide Amy an "equal educational opportunity" relative to children without disabilities. Id., at 198, 102 S.Ct. 3034 (internal quotation marks omitted). The school district, for its part, contended that the IDEA "did not create substantive individual rights"; the FAPE provision was instead merely aspirational. Brief for Petitioners in Rowley, O.T. 1981, No. 80-1002, pp. 28, 41.
Neither position carried the day. On the one hand, this Court rejected the view that the IDEA gives "courts carte blanche to impose upon the States whatever burden their various judgments indicate should be imposed." Rowley, 458 U.S., at 190, n. 11, 102 S.Ct. 3034. After all, the statutory phrase "free appropriate public education" was expressly defined in the Act, even if the definition "tend[ed] toward the cryptic rather than the comprehensive." Id., at 188, 102 S.Ct. 3034. This Court went on to reject the "equal opportunity" standard adopted by the lower courts, concluding that "free appropriate public education" was a phrase "too complex to be captured by the word 'equal' whether one is speaking of opportunities or services." Id., at 199, 102 S.Ct. 3034. The Court also viewed the standard as "entirely unworkable," apt to require "impossible measurements and comparisons" that courts were ill suited to make. Id., at 198, 102 S.Ct. 3034.
On the other hand, the Court also rejected the school district's argument that the FAPE requirement was actually no requirement at all. Id., at 200, 102 S.Ct. 3034. Instead, the Court carefully charted a middle path. Even though "Congress was rather sketchy in establishing substantive requirements" under the Act, id., at 206, 102 S.Ct. 3034 the Court nonetheless made clear that the Act guarantees a substantively adequate program of education to all eligible children, id., at 200-202, 207, 102 S.Ct. 3034 ; see id., at 193, n. 15, 102 S.Ct. 3034 (describing the "substantive standard ... implicit in the Act"). We explained that this requirement is satisfied, and a child has received a FAPE, if[*996] the child's IEP sets out an educational program that is "reasonably calculated to enable the child to receive educational benefits." Id., at 207, 102 S.Ct. 3034. For children receiving instruction in the regular classroom, this would generally require an IEP "reasonably calculated to enable the child to achieve passing marks and advance from grade to grade." Id., at 204, 102 S.Ct. 3034 ; see also id., at 203, n. 25, 102 S.Ct. 3034.
In view of Amy Rowley's excellent progress and the "substantial" suite of specialized instruction and services offered in her IEP, we concluded that her program satisfied the FAPE requirement. Id., at 202, 102 S.Ct. 3034. But we went no further. Instead, we expressly "confine[d] our analysis" to the facts of the case before us. Ibid. Observing that the Act requires States to "educate a wide spectrum" of children with disabilities and that "the benefits obtainable by children at one end of the spectrum will differ dramatically from those obtainable by children at the other end," we declined "to establish any one test for determining the adequacy of educational benefits conferred upon all children covered by the Act." Ibid.
C
Petitioner Endrew F. was diagnosed with autism at age two. Autism is a neurodevelopmental disorder generally marked by impaired social and communicative skills, "engagement in repetitive activities and stereotyped movements, resistance to environmental change or change in daily routines, and unusual responses to sensory experiences." 34 C.F.R. § 300.8(c)(1)(i) (2016) ; see Brief for Petitioner 8. A child with autism qualifies as a "[c]hild with a disability" under the IDEA, and Colorado (where Endrew resides) accepts IDEA funding. § 1401(3)(A). Endrew is therefore entitled to the benefits of the Act, including a FAPE provided by the State.
Endrew attended school in respondent Douglas County School District from preschool through fourth grade. Each year, his IEP Team drafted an IEP addressed to his educational and functional needs. By Endrew's fourth grade year, however, his parents had become dissatisfied with his progress. Although Endrew displayed a number of strengths-his teachers described him as a humorous child with a "sweet disposition" who "show[ed] concern[ ] for friends"-he still "exhibited multiple behaviors that inhibited his ability to access learning in the classroom." Supp. App. 182a; 798 F.3d 1329, 1336 (C.A.10 2015). Endrew would scream in class, climb over furniture and other students, and occasionally run away from school. Id., at 1336. He was afflicted by severe fears of commonplace things like flies, spills, and public restrooms. As Endrew's parents saw it, his academic and functional progress had essentially stalled: Endrew's IEPs largely carried over the same basic goals and objectives from one year to the next, indicating that he was failing to make meaningful progress toward his aims. His parents believed that only a thorough overhaul of the school district's approach to Endrew's behavioral problems could reverse the trend. But in April 2010, the school district presented Endrew's parents with a proposed fifth grade IEP that was, in their view, pretty much the same as his past ones. So his parents removed Endrew from public school and enrolled him at Firefly Autism House, a private school that specializes in educating children with autism.
Endrew did much better at Firefly. The school developed a "behavioral intervention plan" that identified Endrew's most problematic behaviors and set out particular strategies for addressing them.
[*997] See Supp. App. 198a-201a. Firefly also added heft to Endrew's academic goals. Within months, Endrew's behavior improved significantly, permitting him to make a degree of academic progress that had eluded him in public school.
In November 2010, some six months after Endrew started classes at Firefly, his parents again met with representatives of the Douglas County School District. The district presented a new IEP. Endrew's parents considered the IEP no more adequate than the one proposed in April, and rejected it. They were particularly concerned that the stated plan for addressing Endrew's behavior did not differ meaningfully from the plan in his fourth grade IEP, despite the fact that his experience at Firefly suggested that he would benefit from a different approach.
In February 2012, Endrew's parents filed a complaint with the Colorado Department of Education seeking reimbursement for Endrew's tuition at Firefly. To qualify for such relief, they were required to show that the school district had not provided Endrew a FAPE in a timely manner prior to his enrollment at the private school. See § 1412(a)(10)(C)(ii). Endrew's parents contended that the final IEP proposed by the school district was not "reasonably calculated to enable [Endrew] to receive educational benefits" and that Endrew had therefore been denied a FAPE. Rowley, 458 U.S., at 207, 102 S.Ct. 3034. An Administrative Law Judge (ALJ) disagreed and denied relief.
Endrew's parents sought review in Federal District Court. Giving "due weight" to the decision of the ALJ, the District Court affirmed. 2014 WL 4548439, *5 (D.Colo., Sept. 15, 2014) (quoting Rowley, 458 U.S., at 206, 102 S.Ct. 3034 ). The court acknowledged that Endrew's performance under past IEPs "did not reveal immense educational growth." 2014 WL 4548439, at *9. But it concluded that annual modifications to Endrew's IEP objectives were "sufficient to show a pattern of, at the least, minimal progress." Ibid. Because Endrew's previous IEPs had enabled him to make this sort of progress, the court reasoned, his latest, similar IEP was reasonably calculated to do the same thing. In the court's view, that was all Rowley demanded. 2014 WL 4548439, at *9.
The Tenth Circuit affirmed. The Court of Appeals recited language from Rowley stating that the instruction and services furnished to children with disabilities must be calculated to confer "some educational benefit." 798 F.3d, at 1338 (quoting Rowley, 458 U.S., at 200, 102 S.Ct. 3034 ; emphasis added by Tenth Circuit). The court noted that it had long interpreted this language to mean that a child's IEP is adequate as long as it is calculated to confer an "educational benefit [that is] merely ... more than de minimis. " 798 F.3d, at 1338 (internal quotation marks omitted). Applying this standard, the Tenth Circuit held that Endrew's IEP had been "reasonably calculated to enable [him] to make some progress." Id., at 1342 (internal quotation marks omitted). Accordingly, he had not been denied a FAPE.
We granted certiorari. 579 U.S. ----, 137 S.Ct. 29, 195 L.Ed.2d 901 (2016).
II
A
The Court in Rowley declined "to establish any one test for determining the adequacy of educational benefits conferred upon all children covered by the Act." 458 U.S., at 202, 102 S.Ct. 3034. The school district, however, contends that Rowley nonetheless established that "an IEP need not promise any particular level of benefit,"
[*998] so long as it is " ' reasonably calculated' to provide some benefit, as opposed to none ." Brief for Respondent 15.
The district relies on several passages from Rowley to make its case. It points to our observation that "any substantive standard prescribing the level of education to be accorded" children with disabilities was "[n]oticeably absent from the language of the statute." 458 U.S., at 189, 102 S.Ct. 3034 ; see Brief for Respondent 14. The district also emphasizes the Court's statement that the Act requires States to provide access to instruction "sufficient to confer some educational benefit," reasoning that any benefit, however minimal, satisfies this mandate. Brief for Respondent 15 (quoting Rowley, 458 U.S., at 200, 102 S.Ct. 3034 ). Finally, the district urges that the Court conclusively adopted a "some educational benefit" standard when it wrote that "the intent of the Act was more to open the door of public education to handicapped children ... than to guarantee any particular level of education." Id., at 192, 102 S.Ct. 3034 ; see Brief for Respondent 14.
These statements in isolation do support the school district's argument. But the district makes too much of them. Our statement that the face of the IDEA imposed no explicit substantive standard must be evaluated alongside our statement that a substantive standard was "implicit in the Act. " Rowley, 458 U.S., at 193, n. 15, 102 S.Ct. 3034. Similarly, we find little significance in the Court's language concerning the requirement that States provide instruction calculated to "confer some educational benefit." Id., at 200, 102 S.Ct. 3034. The Court had no need to say anything more particular, since the case before it involved a child whose progress plainly demonstrated that her IEP was designed to deliver more than adequate educational benefits. See id., at 202, 209-210, 102 S.Ct. 3034. The Court's principal concern was to correct what it viewed as the surprising rulings below: that the IDEA effectively empowers judges to elaborate a federal common law of public education, and that a child performing better than most in her class had been denied a FAPE. The Court was not concerned with precisely articulating a governing standard for closer cases. See id., at 202, 102 S.Ct. 3034. And the statement that the Act did not "guarantee any particular level of education" simply reflects the unobjectionable proposition that the IDEA cannot and does not promise "any particular [educational] outcome." Id., at 192, 102 S.Ct. 3034 (internal quotation marks omitted). No law could do that-for any child.
More important, the school district's reading of these isolated statements runs headlong into several points on which Rowley is crystal clear. For instance-just after saying that the Act requires instruction that is "sufficient to confer some educational benefit"-we noted that "[t]he determination of when handicapped children are receiving sufficient educational benefits ... presents a ... difficult problem." Id., at 200, 202, 102 S.Ct. 3034 (emphasis added). And then we expressly declined "to establish any one test for determining the adequacy of educational benefits" under the Act. Id., at 202, 102 S.Ct. 3034 (emphasis added). It would not have been "difficult" for us to say when educational benefits are sufficient if we had just said that any educational benefit was enough. And it would have been strange to refuse to set out a test for the adequacy of educational benefits if we had just done exactly that. We cannot accept the school district's reading of Rowley .
B
While Rowley declined to articulate an overarching standard to evaluate the[*999] adequacy of the education provided under the Act, the decision and the statutory language point to a general approach: To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances.
The "reasonably calculated" qualification reflects a recognition that crafting an appropriate program of education requires a prospective judgment by school officials. Id., at 207, 102 S.Ct. 3034. The Act contemplates that this fact-intensive exercise will be informed not only by the expertise of school officials, but also by the input of the child's parents or guardians. Id., at 208-209, 102 S.Ct. 3034. Any review of an IEP must appreciate that the question is whether the IEP is reasonable, not whether the court regards it as ideal. Id., at 206-207, 102 S.Ct. 3034.
The IEP must aim to enable the child to make progress. After all, the essential function of an IEP is to set out a plan for pursuing academic and functional advancement. See §§ 1414(d)(1)(A)(i)(I)-(IV). This reflects the broad purpose of the IDEA, an "ambitious" piece of legislation enacted "in response to Congress' perception that a majority of handicapped children in the United States 'were either totally excluded from schools or [were] sitting idly in regular classrooms awaiting the time when they were old enough to "drop out." ' " Rowley, 458 U.S., at 179, 102 S.Ct. 3034 (quoting H.R.Rep. No. 94-332, p. 2 (1975)). A substantive standard not focused on student progress would do little to remedy the pervasive and tragic academic stagnation that prompted Congress to act.
That the progress contemplated by the IEP must be appropriate in light of the child's circumstances should come as no surprise. A focus on the particular child is at the core of the IDEA. The instruction offered must be "specially designed" to meet a child's "unique needs" through an "[i ] ndividualized education program." §§ 1401(29), (14) (emphasis added). An IEP is not a form document. It is constructed only after careful consideration of the child's present levels of achievement, disability, and potential for growth. §§ 1414(d)(1)(A)(i)(I)-(IV), (d)(3)(A)(i)-(iv). As we observed in Rowley, the IDEA "requires participating States to educate a wide spectrum of handicapped children," and "the benefits obtainable by children at one end of the spectrum will differ dramatically from those obtainable by children at the other end, with infinite variations in between." 458 U.S., at 202, 102 S.Ct. 3034.
Rowley sheds light on what appropriate progress will look like in many cases. There, the Court recognized that the IDEA requires that children with disabilities receive education in the regular classroom "whenever possible. " Ibid. (citing § 1412(a)(5) ). When this preference is met, "the system itself monitors the educational progress of the child." Id., at 202-203, 102 S.Ct. 3034. "Regular examinations are administered, grades are awarded, and yearly advancement to higher grade levels is permitted for those children who attain an adequate knowledge of the course material." Id., at 203, 102 S.Ct. 3034. Progress through this system is what our society generally means by an "education." And access to an "education" is what the IDEA promises. Ibid. Accordingly, for a child fully integrated in the regular classroom, an IEP typically should, as Rowley put it, be "reasonably calculated to enable the child to achieve passing marks and advance from grade to grade." Id., at 203-204, 102 S.Ct. 3034.
[*1000] This guidance is grounded in the statutory definition of a FAPE. One of the components of a FAPE is "special education," defined as "specially designed instruction ... to meet the unique needs of a child with a disability." §§ 1401(9), (29). In determining what it means to "meet the unique needs" of a child with a disability, the provisions governing the IEP development process are a natural source of guidance: It is through the IEP that "[t]he 'free appropriate public education' required by the Act is tailored to the unique needs of" a particular child. Id., at 181, 102 S.Ct. 3034.
The IEP provisions reflect Rowley 's expectation that, for most children, a FAPE will involve integration in the regular classroom and individualized special education calculated to achieve advancement from grade to grade. Every IEP begins by describing a child's present level of achievement, including explaining "how the child's disability affects the child's involvement and progress in the general education curriculum." § 1414(d)(1)(A)(i)(I)(aa). It then sets out "a statement of measurable annual goals ... designed to ... enable the child to be involved in and make progress in the general education curriculum," along with a description of specialized instruction and services that the child will receive. §§ 1414(d)(1)(A)(i)(II), (IV). The instruction and services must likewise be provided with an eye toward "progress in the general education curriculum." § 1414(d)(1)(A)(i)(IV)(bb). Similar IEP requirements have been in place since the time the States began accepting funding under the IDEA.
The school district protests that these provisions impose only procedural requirements-a checklist of items the IEP must address-not a substantive standard enforceable in court. Tr. of Oral Arg. 50-51. But the procedures are there for a reason, and their focus provides insight into what it means, for purposes of the FAPE definition, to "meet the unique needs" of a child with a disability. §§ 1401(9), (29). When a child is fully integrated in the regular classroom, as the Act prefers, what that typically means is providing a level of instruction reasonably calculated to permit advancement through the general curriculum.[2]
Rowley had no need to provide concrete guidance with respect to a child who is not fully integrated in the regular classroom and not able to achieve on grade level. That case concerned a young girl who was progressing smoothly through the regular curriculum. If that is not a reasonable prospect for a child, his IEP need not aim for grade-level advancement. But his educational program must be appropriately ambitious in light of his circumstances, just as advancement from grade to grade is appropriately ambitious for most children in the regular classroom. 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[*1001] 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.' " Rowley, 458 U.S., at 179, 102 S.Ct. 3034 (some internal quotation marks omitted). 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.
C
Endrew's parents argue that the Act goes even further. In their view, a FAPE is "an education that aims to provide a child with a disability opportunities to achieve academic success, attain self-sufficiency, and contribute to society that are substantially equal to the opportunities afforded children without disabilities." Brief for Petitioner 40.
This standard is strikingly similar to the one the lower courts adopted in Rowley, and it is virtually identical to the formulation advanced by Justice Blackmun in his separate writing in that case. See 458 U.S., at 185-186, 102 S.Ct. 3034 ; id., at 211, 102 S.Ct. 3034 (opinion concurring in judgment) ("[T]he question is whether Amy's program ... offered her an opportunity to understand and participate in the classroom that was substantially equal to that given her non-handicapped classmates"). But the majority rejected any such standard in clear terms. Id., at 198, 102 S.Ct. 3034 ("The requirement that States provide 'equal' educational opportunities would ... seem to present an entirely unworkable standard requiring impossible measurements and comparisons"). Mindful that Congress (despite several intervening amendments to the IDEA) has not materially changed the statutory definition of a FAPE since Rowley was decided, we decline to interpret the FAPE provision in a manner so plainly at odds with the Court's analysis in that case. Compare § 1401(18) (1976 ed.) with § 1401(9) (2012 ed.).
D
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." Rowley, 458 U.S., at 206, 102 S.Ct. 3034.
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. See §§ 1414, 1415 ; id., at 208-209, 102 S.Ct. 3034. 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[*1002] 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.
The judgment of the United States Court of Appeals for the Tenth Circuit is vacated, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
The requirement was initially set out in the Education of the Handicapped Act, which was later amended and renamed the IDEA. See Pub. L. 101-476, § 901(a), 104 Stat. 1141. For simplicity's sake-and to avoid "acronym overload"-we use the latter title throughout this opinion. Fry v. Napoleon Community Schools, 580 U.S. ----, ----, n. 1, 137 S.Ct. 743, 750, n. 1, --- L.E.2d ---- (2017).
This guidance should not be interpreted as an inflexible rule. We declined to hold in Rowley, and do not hold today, that "every handicapped child who is advancing from grade to grade ... is automatically receiving a [FAPE]." Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley, 458 U.S. 176, 203, n. 25, 102 S.Ct. 3034, 73 L.Ed.2d 690 (1982).