The Endrew F decision is the most important US Supreme Court special education decision in 35 years. Through the first five years, 1977-1982, of special education as we know it, parents and schools made things up as they went along in a positive and collegial manner. Then in 1982, the Supreme Court’s Rowley decision changed the atmosphere to one that was more combative. Rowley was broadly interpreted that public schools needed to provide only a floor of opportunity via its special education programs – particularly those for children with more severe disabilities.
What Endrew F ruled was that a floor or de minimus opportunities are insufficient, holding “To meet its substantive obligation under IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” Endrew F. is not specific, it does not prescribe a definition of progress or offer grade level equivalents that are the basis of mainstream schooling. Endrew F. shifts the position of the school district from one that must satisfy a minimum standard to one that must offer reasonable hope of progress. This is good news for children, families, and special educators.