Did you know that on March 22nd, 2017, in an 8-0 ruling in the case of Endrew F. v. Douglas County School District, the U.S. Supreme Court clarified that under the Individuals with Disabilities Education Act (IDEA) an Individualized Education Program (IEP), together with the services and supports it outlines, must do more than offer minimal benefit?
The justices unanimously agreed that the judgement of the U.S. Court of Appeals for the Tenth Circuit should be vacated (overruled) and the case remanded (returned to the Court of Appeals for a new ruling) for additional proceedings consistent with the high court’s opinion.
In plain English, the case involved the family of a student with autism who argued that the public-school district did not provide an appropriate education as their son did not meet IEP goals, the same goals were offered annually, and the student made progress once his parents moved him to a private school with a new IEP and educational approach.
While the Supreme Court decision does not make a ruling on whether the district must reimburse the family for private school tuition or any of the other specifics of this case, it does clarify what is required under the principle of a free and appropriate education (FAPE) and compelled the lower court to relook at it in light of the Supreme Court’s findings on the merits of the case.
And while this ruling may seem like old news, the ripple effects are still being felt, It remains deeply relevant to how we show up today as educators and how we develop meaningful and legally defensible IEPs.
The Before and After: From Rowley to Endrew F.
Before Endrew F., the standard came from a case decided over 30 years earlier: Rowley v. Hendrick Hudson School District (1982). In Rowley, the Court said that schools needed to provide a “basic floor of opportunity.” In other words, if a child was receiving access to services that provided some educational benefit, that was enough.
The Rowley case dealt with a student who was already doing well in general education classes with some supports, so it didn’t say much about students who learn primarily outside the general education classroom. Over the years, courts often used this outdated precedent to justify the bare minimum, especially for students with more complex needs.
That’s why Endrew F. was such a big deal.
The Court made it clear that legally defensible IEPs are those that go beyond minimal benefit and are thoughtfully developed to reflect the individual needs of each student. To meet this standard, legally defensible IEPs:
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Must be “appropriately ambitious” in light of the child’s unique circumstances
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Can be adequately defended by school teams through a clear, cogent, and responsive explanation of their decisions
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Include goals designed to support meaningful progress, rather than repeating the same objectives year after year
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“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.”
– Justice John Roberts
What This Means for You and Your IEP Team
Here’s the heart of it: writing legally defensible IEPs is not a box-checking exercise. It’s a chance to dream big and to make sure those dreams are supported by a plan that works.
The Endrew F. decision reminds us that:
✅ Goals must be meaningful, measurable, and relevant to helping the student access and make progress in the general curriculum.
✅ Each year’s IEP should build on the last. Repeating the same goals with no progress isn’t okay.
✅ All members of the IEP team, including families, bring essential expertise. Respecting and elevating these diverse voices is part of creating a legally defensible and truly inclusive IEP.
✅ Services and supports must be tailored to the child’s strengths and needs, not just based on what’s “available.”
At Inclusive Schooling, we believe the best IEPs are grounded in high expectations, collaboration, and a commitment to seeing each child as capable– because they are.
Bottom line? The Endrew F. decision gives us a powerful reminder that inclusion isn’t just about placement. It’s about progress. And meaningful progress only happens when we design supports that are individualized, responsive, and rooted in a belief in every student’s capacity to learn and grow.
Let’s continue to write legally defensible IEPs that reflect our highest hopes and our deepest commitments to equity and inclusion.
Interested in learning more? These resources are a great place to start…
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What is an IEP? Page 2: Endrew F. & IEP Standards
This IRIS Center page breaks down the Supreme Court’s Endrew F. decision in a way that’s clear and educator-friendly. You’ll get a solid understanding of what it means for IEPs to be “appropriately ambitious” and tailored to each child. The page also links to helpful extras like videos, legal summaries, and tools to support better, more inclusive IEPs. -
The IDEA Demands More: A Review of FAPE Litigation After Endrew F.
Hosted on Wrightslaw, this in-depth analysis by William Moran looks at how courts have handled FAPE cases since Endrew F. While the ruling raised the bar, enforcement has been uneven. This piece helps educators, families, and advocates understand the real impact—and limitations—of the decision in practice. -
An Overview of Endrew F.: Implications for Student Behavior
This short brief from the PBIS Center zooms in on what Endrew F. means for students with behavioral support needs. It stresses the importance of aligning behavioral goals, services, and progress monitoring—and reminds us that FAPE includes strong, evidence-based supports for students with emotional or behavioral challenges.
A Legal Fun Fact (That’s Actually Really Important)
The Individuals with Disabilities Education Act (IDEA) is not actually a civil rights law the way that the American with Disabilities Act (ADA) is. Rather, the IDEA is spending clause legislation that dictates what states must do to maintain federal funding. Therefore, states only need to adhere to the IDEA if they take federal funds. (Spoiler alert: every state does.) That’s why it’s so crucial that we understand the law’s provisions and use them to advocate for inclusive, individualized education.
Also worth knowing: private schools that don’t accept federal funds typically don’t have to follow IDEA. However, if a student with an IEP is placed in a private school by a public district, that district is still responsible for making sure the IEP is followed.
About the Author: Ashley Lyons, M.Ed is a team member at Inclusive Schooling. With over two decades of experience in the fields of special education and early intervention. including a background in educational policy and family engagement, Ashley brings a deep commitment to ensuring that all students receive meaningful, individualized support. She is especially passionate about the thoughtful integration of human-centered AI in education, exploring how emerging technologies can be used to amplify educator capacity, promote accessibility, and honor neurodiversity. You can connect with Ashley on LinkedIn.