“This decision is a victory for students on the autism spectrum. It reaffirms that all publicly funded schools have an obligation to provide all students the supports they need to help them achieve in the classroom. The decision renews our public commitment to help everyone work to reach their potential.”
In Endrew, the Court grapples with what level of services are due students with special needs. Under the Individuals with Disabilities Education Act (IDEA), all students must have access to a free, appropriate public education in the least restrictive environment – usually taken to mean they should be as integrated as possible with their peers who do not have special needs. The underlying expectation and educational philosophy is that they should be able to access the general curriculum to the greatest extent possible and make meaningful progress.
The analysis becomes more difficult when the needs of a given student are severe enough that he or she cannot realistically be integrated and/or access that curriculum. The question the Court sought to answer in Endrew is what level of progress should be the goal of the supports the schools are required to provide these students – and by extension all students with special needs. The Court held that, “to meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” In so doing, the Court rejected the idea that students with special needs – including those with the greatest needs – are only entitled to services designed to help them achieve the bare minimum amount of progress.