Board of Education of the Hendrick Hudson Central School District v. Rowley

Board of Education of the Hendrick Hudson Central School District v. Rowley, legal case in which the U.S. Supreme Court on June 28, 1982, held (6–3) that the Education of the Handicapped Act of 1974 (EHA; renamed the Individuals with Disabilities Education Act [IDEA] in 1990), as amended by the Education for All Handicapped Children Act of 1975, did not require that the special instruction and supportive services provided under the law by state governments to disabled students be designed to help them achieve their full potential as learners. Instead, it was sufficient that the instruction and services be such as “to permit the child to benefit educationally from that instruction.” The ruling marked the first time that the court had interpreted any portion of the EHA.

Under the EHA, state governments, through local school boards, were required to provide disabled students with a “free appropriate public education” (FAPE) in the “least restrictive environment”—i.e., in classrooms with nondisabled children, where feasible—as detailed in an individualized education program (IEP) developed for each child by school officials in consultation with parents or guardians. The court’s decision in Rowley thus defined the term free appropriate public education.

Background

Amy Rowley was a deaf student in a public school in Peekskill, New York. Prior to the beginning of her kindergarten year, Rowley’s parents (who themselves were deaf) met with school administrators to develop an IEP for her, which provided for a sign-language interpreter in the classroom. Following a two-week trial period, however, the interpreter reported that Rowley did not need his services. For the remainder of the school year, she relied on an FM wireless hearing aid as well as her ability to read lips.

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At the beginning of her first-grade year, a new IEP for Rowley was prepared, as required by the EHA. Rowley was again to be given an FM wireless hearing aid for use in the classroom; additionally, she was to receive instruction from a tutor for one hour per day and speech therapy for three hours per week. Rowley’s parents requested that the school provide her with a sign-language interpreter instead of other forms of assistance identified in the IEP. After school administrators refused the request, the Rowleys sought administrative review of the decision as permitted by the EHA. They argued that, with a hearing aid but without an interpreter, Rowley would be able to understand only about 60 percent of the spoken language in the classroom. An independent examiner agreed with the school that an interpreter was unnecessary, a decision that was affirmed on appeal by the New York commissioner of education.

The Rowleys then filed suit in U.S. district court, naming the school district as defendant. The district court judge found that, because Rowley lacked an interpreter, “she understands considerably less of what goes on in class than she could if she were not deaf,” and she “is not learning as much, or performing as well academically, as she would without her handicap.” The judge concluded that Rowley was not receiving a “free appropriate public education,” which he defined in her case as “an opportunity to achieve [her] full potential commensurate with the opportunity provided to other children.” The Court of Appeals for the Second Circuit affirmed that judgment in July 1980. The school district then appealed to the Supreme Court, which heard oral arguments on March 23, 1982.

Majority opinion

In an opinion for a 6–3 majority written by Justice William Rehnquist, the Supreme Court reversed the Second Circuit’s decision. Rehnquist argued that both the district court and the Second Circuit had inappropriately ignored the definition of “free appropriate public education” provided in the EHA itself on the erroneous assumption that it did not adequately explain the exact meaning of appropriate and other terms. According to the EHA’s definition,

the term “free appropriate public education” means special education and related services which (A) have been provided at public expense, under public supervision and direction, and without charge, (B) meet the standards of the State educational agency, (C) include an appropriate preschool, elementary, or secondary school education in the State involved, and (D) are provided in conformity with the individualized education program required under section 1414(a)(5) of this title.

The term special education is then defined as

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specially designed instruction, at no cost to parents or guardians, to meet the unique needs of a handicapped child, including classroom instruction, instruction in physical education, home instruction, and instruction in hospitals and institutions.

And related services is defined as

transportation, and such developmental, corrective, and other supportive services…as may be required to assist a handicapped child to benefit from special education.

According to these definitions, Rehnquist concluded,

a “free appropriate public education” consists of educational instruction specially designed to meet the unique needs of the handicapped child, supported by such services as are necessary to permit the child “to benefit” from the instruction.

“Noticeably absent from the language of the statute,” he continued, “is any substantive standard prescribing the level of education to be accorded handicapped children.” Nor did the legislative history of the EHA indicate that Congress intended the special instruction and supportive services provided under the law to enable each disabled child to reach his full potential. Rather, “the intent of the Act was more to open the door of public education to handicapped children on appropriate terms than to guarantee any particular level of education once inside.”

Rehnquist’s opinion was joined by Chief Justice Warren E. Burger and Justices Sandra Day O’Connor, Lewis F. Powell, Jr., and John Paul Stevens. Justice Harry A. Blackmun filed an opinion concurring in the judgment.

In later years, the “educational benefit” standard established in Rowley was variously interpreted by the federal courts. Some courts, for example, understood the standard to require that an appreciable, meaningful, or more-than-trivial benefit be conferred by the education provided, and others took it to require progress, effective results, or demonstrable improvements in academic performance.