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Analysis of Case Law - Special Education Needs

Endrew F. v. Douglas County School District RE-1(2017)

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This paper is an analysis of a court case between the school district of Douglas County and the family of student Endrew F. who suffered from Autism related disabilities. The case Endrew F. v. Douglas County School District RE-1 emphasized the views of the parents who argued that their child who suffered from autism did not make measurable progress on his IEP (Individualized Education Program) goals and the school did not address his behavioral problems and issues.

Special Education Student
The parents of the autistic student Endrew removes him from a regular school after he showed severe behavioral issues. Endrew was enrolled in a special needs school in Denver with an annual tuition of $70,000. The parents demanded tuition reimbursement, claiming that the school did not fulfill the requirements of IDEA (Individuals with Disabilities Education Act, 1990). They advocated and supported a "meaningful educational benefit" standard that can be expected from schools.This case provides a wide ranging debate on educational benefits for the disabled and the school's responsibilities of fulfilling special educational needs of students with disabilities.

Special Education - Current Debates

Special education is the practice of providing special provisions to certain students with individual needs and disabilities. The process includes individually planned and systematically monitored special arrangements and teaching procedures. Special education addresses learning problems and disabilities as is expected to provide special educational benefits to students with needs or disabilities. Children with ADHD, Autism, reading difficulties, dyslexia, visual or hearing difficulties and developmental disorders have special needs (Winzer, 2014). In certain developed nations, teachers use Individualized Education Program or IEP for students with special needs. Along with individualized programs, students may have to go through speech therapy, occupational therapy and individual learning plan. The estimated costs of providing special education to children with disabilities is 3 times higher than costs of providing education to regular children.

Provisions of assistive technology to such students are helpful but expensive, although assistive technology is a tool that enables the children to perform tasks independently. Technology integration increases motivation and self-confidence of students and inclusion of technology has become a focal point in special education learning and education programs.

Special education needs may be related to social skills deficit and this have negative impact on obtaining or keeping jobs (Elksnin and Elksnin, 2001) and long-term or future prospects. One of the areas of special education is to develop social skills in students.

Current debates on special education primarily revolve around six issues - 1. the financial challenges of schools and governments in maintaining special education programs, 2. Resource availability and teaching provisions as well as availability of trained teachers. Pavri (2004) claimed that 56% of teachers believed they had fair to poor resource availability or preparation for teaching students with disabilities and special needs, 3. Filling the race gap between minority and White students. Minority students are more likely to have special education needs and disabilities such as learning disabilities and autism or developmental disorders, yet less likely than white students to receive special education, so there is possibly a racial and even socio-economic gap on how special needs are fulfilled for students from White and minority ethnic backgrounds (Pavri, 2004; Losen & Orfield, 2002). Some educationalists have claimed that students with special needs show lower drop out rates when compared with normal students. The learning gap is also closing in between normal and disabled students. 4. Researchers have argued that students with special needs still lack the adequate resources required for effective learning. 5. Exam or assessment methods to judge the abilities of special needs students are not adequate or appropriate and need considerable rethinking. 5. The other issue is on the effectiveness of special education programs and whether these teaching procedures are genuinely fulfilling the special needs of students.

Summary of Court Case

This particular case deals with the efficacy of special education programs as given by schools as the parents of student Endrew F. argued that special education for their child did not fulfill the IEP goals and did not have the requisite special education benefit that such schools or programs must provide.

The parents requested the Supreme Court to resolve their educational benefit question and the Supreme Court ruled that the school must be able to meet parental and student expectations and provide the requisite benefits of special educational needs to students. The court ruling stated that to meet its substantive obligation under the IDEA (Individuals with Disabilities Education Act), a school must offer an IEP that is effective in enabling a child to make progress appropriate in light of the child's circumstances" (Endrew F. v. Douglas County School Dist. RE-1, No. 15-827, 580 U.S. (2017), slip. op. at 11).

In this case - Endrew F. v. Douglas County School District RE-1 (No. 15-827) (2017), U.S. Supreme Court unanimously rejected the "de minimis" standard of special education and Chief Justice Roberts stated "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."

Opinions and Arguments

The SCOTUS decision is a landmark ruling in special education needs and implementation of IDEA, as it suggests the way forward or future direction in special education, as future IEP programs and teaching procedures must align with the goals of education. As argued by the parents in this court case, disabled or special needs students must be able to derive benefits from their educational institutions through the resources given to them. The Endrew F. v. Douglas County School District RE-1, No. (15-827) (2017) is a significant case in special education highlighting the expectation gap between special benefits and the special needs met by schools through their programs, resources and teaching methods.


In this Endrew F. v. Douglas County School District RE-1 case, the parents argued that their child suffering from autism did not receive the special educational benefits or the standard of education he was expected to receive. After an adverse decision from a federal appeals court, the parents requested the Supreme Court to resolve the question. The Supreme Court ruled in favor of educational benefits and provisions of sufficient resources to disabled students.


Elksnin, N., & Elksnin, L. (2001). Adolescents with disabilities: The need for social skills training. Ex- ceptionality, 9, 91-105.

Endrew F. v. Douglas County School Dist. RE-1, No. 15-827, 580 U.S. (2017).

Essay Ads. Governance in Higher Education by Board Members with Faculty Participation. Online:

IDEA (2004). Regulations: Subpart E - Procedural Safeguards.

Losen, Daniel J. & Orfield, Gary (2002), Introduction to Racial Inequality in Special Education. The Civil Rights Project at Harvard University: Harvard Education Press.

Pavri, S (2004). General and Special Education Teachers' Preparation Needs in Providing Social Support: A Needs Assessment. Teacher Education and Special Education. 27(4).

Winzer, Margret, A. (2014). The History of Special Education : From Isolation to Integration. Gallaudet University Press.

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Education Student
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Special education graduate student, part-time law adjunct, and researcher.

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