Reflection Cycle Special Education Court Case

Dr. Reed
Submitted by Kelly Thurber

Artifact:

Massachusetts Advocates for Children

Describe:
(1982)

The Rowley Decision : Board of Education v Rowley, 458 U.S. 176

This was the first Supreme Court opinion regarding the contours of the

IDEA
Act and the FAPE mandate within it. The Court opined that the IDEA
requires
proposed special education and related services to be reasonably
calculated to
enable the student to receive educational benefits. This phrase
reasonably calculated has generally been understood to mean that the IDEA does
not guarantee
any particular result rather, the educational services proposed by a
school district
must only be reasonably likely to provide sufficient benefit to the
student. The key
remaining question, of course, is how much benefit is sufficient under
the IDEAs
FAPE mandate. In language that lower courts continue to quote, the
Supreme Court
Explained: Whatever Congress meant by an appropriate education, it
is clear that it
did not mean a potential maximizing education. The Supreme Court
added that a
student must receive some benefit and several Circuit Courts have
adopted this

language in a manner that tends to limit the FAPE entitlement. But,

the Supreme
Court also used the term meaningful to describe what education
must be provided,
and referenced a standard of meaningful access to public education.
Many courts have
adopted a meaningful benefit standard. Importantly, the Bureau of
Special Education
Appeals hearing officers have also adopted a meaningful benefit
standard. Two other
parts of the Rowley decision help one understand the contours of the
FAPE standard.
First, the Court wrote that FAPE must be tailored to the unique needs of
the handicapped child by means of an individualized educational program (IEP).
This emphasizes the
critical principle of individuality.
Analyze:
so that we

It is important to understand these early cases in special education law

understand as educators how far we have come and how much further
we need to go.
Knowing important case law is important to understanding how my
students needs
will be met and what the requirements of the school districts are. As a
Diagnostician,
this is paramount.
Appraise:

Understanding special education case law is extremely beneficial

Transform: I will keep the top 10 special education law cases in my professional
library to refer
to and remind me why special education is important.