- Has the State complied with the procedures set forth in IDEA? 
- Is the individualized education program (IEP) developed through IDEA’s procedures reasonably calculated so that the child can receive educational benefits? 


If these requirements are not met and the violation has resulted in some form of significant harm to the student, the State has not complied with the obligations set forth by Congress. 

University of Michigan - Ann Arbor

Board of Education v. Rowley (1982) was a landmark case that defined “free appropriate public education” (FAPE) seven years after it was first written into policy under the Education for All Handicapped Children Act (now IDEA). 

Board of Education v. Rowley

Idaho State Department of Education, The Rowley Case: What Does It Really Mean? (2020). Boise, Idaho. 

The Rowley Case: What Does It Really Mean?

Amy Rowley was a deaf student at the Furnace Woods School in the Hendrick Hudson Central School District. She had minimal residual hearing, but excelled in lip reading. Before she began attending the school, her parents and the school administrators decided to place her in the regular kindergarten class to determine what supplemental services they would need to provide her. Several members of the school administration attended a course in sign-language interpretation prior to her arrival, and a teletype machine was installed in the principal’s office so they could communicate with Amy’s parents, who were also deaf. At the end of this trial period, they determined that Amy should remain in the kindergarten class, and she would be provided an FM hearing aid, which amplified words spoken into a wireless receiver by the teacher or her peers during classroom activities. 

Background of Board of Education v. Rowley

Rowley Questions

Prior to this ruling, the term “free appropriate public education” had not been properly defined, despite being written into policy. The Supreme Court ruling thus defined it as consisting of educational instruction specially designed to meet the unique needs of the child with disability, while being supported by services necessary for the child “to benefit” from the instruction. FAPE, therefore, does not entitle the student the potential to maximize their education. 

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