## Facts

- Endrew F., a child with autism and related disabilities, attended Douglas County public schools from preschool through fourth grade under annual individualized education programs (IEPs).
- By fourth grade, Endrew’s parents believed his educational progress had largely stalled; behavioral problems interfered with learning, and several IEP goals were repeated from year to year.
- The school district proposed a fifth-grade IEP that the parents viewed as largely similar to prior plans.
- The parents withdrew Endrew from public school and enrolled him at Firefly Autism House, a private program specializing in autism, where he received a new behavioral plan and more intensive programming and made significant progress.
- The parents sought tuition reimbursement under the Individuals with Disabilities Education Act (IDEA), alleging the district denied Endrew a free appropriate public education (FAPE).
- Administrative proceedings and the federal district court denied reimbursement, applying a standard that an IEP must provide an educational benefit “merely more than de minimis.”
- The Tenth Circuit affirmed under the same “merely more than de minimis” standard.

## Issues

1. What substantive standard governs whether an IEP provides FAPE under IDEA.
2. Whether IDEA is satisfied by an IEP that is calculated to confer an educational benefit “merely more than de minimis.”
3. How courts should evaluate the adequacy of an IEP for a child whose circumstances make grade-level advancement in a regular classroom unrealistic.

## Decision

- The Supreme Court unanimously vacated the Tenth Circuit’s judgment and remanded.
- The Court rejected the “merely more than de minimis” educational benefit standard as inconsistent with IDEA.
- The Court held that, to satisfy IDEA’s substantive obligation, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.
- The Court declined to adopt a rule requiring schools to provide opportunities substantially equal to those offered to children without disabilities.

## Legal Principles

- FAPE under IDEA requires an IEP reasonably calculated to enable progress appropriate in light of the child’s circumstances.
- The IEP inquiry is individualized and turns on the unique circumstances of the particular child; no single quantitative metric governs all cases.
- For a child fully integrated in the regular classroom, an IEP will typically be adequate if it is reasonably calculated to enable the child to achieve passing marks and advance from grade to grade.
- When grade-level advancement is not a reasonable prospect, the IEP must still be appropriately ambitious and aimed at academic and functional advancement, not trivial gains.
- Judicial review asks whether the IEP is reasonable, not whether it is ideal; courts should give due weight to educational expertise while enforcing IDEA’s substantive requirements.

## Conclusion

The Court clarified that IDEA demands more than minimal educational benefit: an IEP must be designed, based on the child’s individual circumstances, to enable appropriately ambitious progress, and the “merely more than de minimis” standard is insufficient.


Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE-1, 580 U.S. 386 (2017)