SCOTUS Hears Argument About “Educational Benefit” Under the IDEA  

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The Legal Intelligencer
February 13, 2017

On January 11, 2017, the Supreme Court of the United States heard argument regarding the proper standard for measuring educational benefits for children with disabilities pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400 et seq.   Specifically, the justices were tasked with deciding whether the “educational benefit” provided by a school district must be “merely more than de minimis” or “meaningful” to satisfy the requirements for a free appropriate public education (FAPE) under the IDEA. 

By way of background, the underlying case, Edward F. v. Douglas Co. Sch. Dist. RE-1, involved a child with attention deficit/hyperactivity disorder and autism who was attending public school in Douglas County, Colorado.  From preschool through fourth grade, the student was provided with an Individualized Education Program (IEP) by the public school but his parents decided that he was not making meaningful academic progress, as his behavioral problems were escalating and were impeding his learning.  Accordingly, his parents rejected the school’s proposed IEP for his fifth grade year and they decided to enroll him in a private school.   

Subsequently, the parents filed a Due Process Complaint with the Colorado Department of Education and, after a three-day hearing, the hearing officer decided that the student made “some academic progress” at the public school and that the school was only required to provide “some educational benefit” under the IDEA.  The parents appealed the ruling to the United States District Court for the District of Arizona, and the court upheld the decision of the hearing officer.  The District Court noted that the IDEA only requires a school district to provide “some educational benefit” and that since the student made “at least, minimal progress” in the public school, the IDEA requirements were met. 

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Reprinted with permission from the February 13, 2017 edition of The Legal Intelligencer© 2017 ALM Media Properties, LLC. All rights reserved. Further duplication without permission is prohibited. ALMReprints.com - 877-257-3382 - reprints@alm.com.