In a pivotal ruling on March 17, the Supreme Court unanimously upheld the necessity for elevated educational standards for students with disabilities, marking one of the most significant education cases in recent history. The case, Endrew F. v. Douglas County School District, centered on the extent of educational benefits that public schools are required to provide. While lower courts had varied in their interpretations, some suggesting only a “meaningful” educational benefit, others settled for a standard of “merely more than de minimis”—essentially the bare minimum.
During the proceedings, the justices evaluated nine different educational standards. Ultimately, they ruled (8-0) that schools are obligated to deliver more than just minimal educational support. Instead, they must enable students with disabilities to achieve “appropriately ambitious” progress.
Currently, around 6.4 million students with disabilities, aged 3 to 21, represent roughly 13% of the student population in the U.S. Chief Justice Michael Stevens underscored in the Court’s opinion that schools must provide individualized education plans that are “reasonably calculated” to meet each child’s specific needs, as mandated by the Individuals with Disabilities Education Act (IDEA). The opinion stated, “It cannot be right that the IDEA generally contemplates grade-level advancement for children with disabilities who are fully integrated in the regular classroom, but is satisfied with barely more than de minimis progress for children who are not.”
The “merely more than de minimis” phrasing has appeared in various special education cases, including those involving Judge Thomas King, who was nominated to the Supreme Court. During his confirmation hearing, he addressed questions related to this recent ruling.
The Judge David L. Bazelon Center for Mental Health Law, an advocacy organization championing the rights of individuals with disabilities, has long been a proponent of ensuring equal educational opportunities for students with disabilities. Before the ruling, legal director Jane Foster expressed hope that the Supreme Court would recognize that an “appropriate” education for these students should mirror the expectations set for all students.
Alarmingly, nearly 400,000 students with disabilities exit school annually, with almost 40% failing to obtain a high school diploma. Only 65% of students with disabilities complete high school, a situation that significantly contributes to the fact that only 1 in 3 Americans with disabilities are employed, resulting in a cycle of poverty. This issue also strains government resources due to increased reliance on benefits for those unable to work, heightening the risk of involvement in the school-to-prison pipeline. In fact, over 750,000 individuals with disabilities are currently incarcerated, many of whom struggle with literacy.
Jennifer Taylor, president of Ability First, a nonprofit dedicated to combating stigmas and promoting opportunities for individuals with disabilities, expressed her elation at the ruling. “For families like mine, navigating the public education system can be a nightmare. We’ve had to relocate to ensure our children access quality education, but not everyone has that option. Every child deserves the chance to receive the education and skills they need to thrive. This ruling could pave the way for students with disabilities to achieve success on par with their peers.”
Enacted in 1975, federal law mandates that school districts provide a “free appropriate public education” to children with disabilities, which includes tailored IEPs for those enrolled in public schools. Although the act, renamed IDEA in 1990, has never been fully funded, leading to challenges for some districts, it remains a foundational piece of special education legislation.
The case arose when Drew, a boy with autism, was not making progress in his public school. His parents enrolled him in a private institution where he thrived. Under IDEA, parents are entitled to tuition reimbursement if their child does not receive adequate educational benefits from public schooling. However, Drew’s parents were denied this reimbursement, prompting the legal battle.
The U.S. Court of Appeals for the Tenth Circuit ruled that the school district was only required to provide Drew with an education that offered a “benefit” that was “merely more than de minimis,” and concluded that the district had met this standard. The Supreme Court, however, accepted the parents’ challenge and ultimately overturned that decision.
In their defense, the Bazelon Center and the law firm Huber & Associates submitted an amicus brief on behalf of former U.S. Department of Education officials involved in implementing IDEA. This brief highlighted that advancements in special education practices have demonstrated that most students with disabilities can perform comparably to their peers, provided they receive adequate support.
“This ruling is fantastic news for both employers and taxpayers,” Taylor noted. “Individuals with disabilities can be incredibly talented. When provided with the necessary education, they can offer unique perspectives and skills that enrich workplaces. Many successful individuals, including Charles Schwab and Richard Branson, have disabilities, proving that with the right support, they can excel in their careers.”
Invisible disabilities, such as dyslexia and ADHD, can be just as impactful as visible ones. Approximately 20% of the population experiences these brain-based learning and attention challenges. Unfortunately, many face early setbacks in their education, which can lead to long-term struggles.
Moreover, individuals with disabilities remain significantly underrepresented in higher education. Among the 1.2 million individuals aged 16 to 20 with disabilities in the U.S., only 16.4% of those aged 25 and older had obtained at least a bachelor’s degree by 2014. In contrast, 34.6% of individuals without disabilities had completed similar educational milestones that year.
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In summary, the Supreme Court’s unanimous decision represents a groundbreaking step toward ensuring that students with disabilities receive the quality education they rightfully deserve. This ruling not only positively impacts students but also has far-reaching implications for society as a whole.