## Facts

- Amy Rowley, a deaf student in a New York public school, had minimal residual hearing and used an FM hearing aid.
- The school provided related supports, including instruction from a tutor for the deaf and speech therapy, through an individualized education program (IEP).
- Amy’s parents requested a full-time qualified sign-language interpreter for all academic classes.
- School officials, after evaluations including input from a sign-language expert, denied the request, concluding Amy could succeed without a full-time interpreter.
- Administrative officers upheld the school district’s denial.
- In federal court, evidence showed Amy was performing better than the average child in her class and advancing from grade to grade, though the district court found she was not achieving as well as she might without her disability.
- The district court and the Second Circuit held that FAPE required an opportunity to achieve full potential commensurate with non-disabled peers and ordered the interpreter.
- The Supreme Court granted review to determine the substantive meaning of FAPE under the Education for All Handicapped Children Act of 1975 (EAHCA).

## Issues

1. What substantive standard does the EAHCA’s requirement of a “free appropriate public education” (FAPE) impose on states receiving federal funds?
2. Whether the EAHCA required a school district to provide a full-time sign-language interpreter to a deaf student who was progressing academically with existing services.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that FAPE is satisfied when the state provides personalized instruction, with sufficient support services, to permit the child to benefit educationally from that instruction, delivered at public expense and in conformity with the child’s IEP.
- The Court rejected the lower courts’ “full potential” standard as unsupported by the statute and more demanding than Congress intended.
- The Court set out a two-part inquiry for judicial review: (1) whether the state complied with the Act’s procedures, and (2) whether the IEP was reasonably calculated to enable the child to receive educational benefits.
- Applying that framework, the Court concluded Amy was receiving educational benefit and advancing from grade to grade; therefore, the Act did not require a full-time interpreter.

## Legal Principles

- The EAHCA/IDEA does not require schools to maximize a disabled child’s potential or ensure outcomes equal to those of non-disabled children.
- Courts reviewing FAPE claims apply a two-part test: procedural compliance with the Act’s safeguards and an IEP reasonably calculated to enable educational benefit.
- When procedural requirements are met and the IEP is substantively adequate, courts should not replace educators’ judgments on educational methods with their own.
- An IEP that provides personalized instruction and adequate related services to permit educational benefit can satisfy FAPE even if additional services might yield greater achievement.

## Conclusion

The Court held that FAPE under the EAHCA requires an IEP reasonably calculated to provide educational benefit, not an education designed to achieve a child’s full potential, and it therefore declined to require a full-time sign-language interpreter for a student who was successfully progressing with existing supports.


Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (1982)