If you’re a parent, educator, or advocate involved in special education, you’ve likely heard of the Individuals with Disabilities Education Act (IDEA). Enacted in 1975 and significantly revised in 1990, IDEA ensures that children with disabilities receive a free appropriate public education (FAPE) tailored to their individual needs. But what exactly does this mean in practice, and how have courts shaped its interpretation?
IDEA provides essential protections and services to students, empowering families and educators to collaborate effectively. However, navigating its complexities can be challenging. Judicial decisions, especially those from the U.S. Supreme Court and the Circuit Courts of Appeals, continuously influence how IDEA is implemented, directly impacting educational rights and services.
In this blog series, we’ll examine key Supreme Court and Second Circuit decisions that have profoundly influenced special education law. We’ll begin by focusing on cases from the Second Circuit, as I live and practice in New York City, which falls within this jurisdiction.
Each post will highlight crucial cases, summarize essential legal principles, and explain their practical implications for students, families, and schools.
This introductory post will serve as a foundational reference, providing context to help you better understand IDEA and the importance of staying informed about judicial developments.
Below is an outline of the initial cases I will review in upcoming posts:
Supreme Court Cases:
- Board of Education v. Rowley (1982): Establishing the concept of “Free Appropriate Public Education (FAPE)”
- Endrew F. v. Douglas County School District (2017): Defining appropriate educational standards, and clarifying Rowley’s standard
- Honig v. Doe (1988): Discipline and procedural safeguards
- Florence County School District Four v. Carter (1993): Reimbursement for private placements
- Cedar Rapids Community School Dist. v. Garret F. (1999): Related services
- Schaffer v. Weast (2005): Burden of proof
- Forest Grove School Dist. v. T.A. (2009): Tuition reimbursement without prior public placement
- Perez v. Sturgis Public Schools (2023): IDEA exhaustion and ADA remedies
Second Circuit Cases:
- Walczak v. Florida Union Free School District (1998): Clarifying educational benefit requirements
- Cerra v. Pawling Central School District (2005): Addressing procedural and substantive disputes and parental rights
- P. v. Newington Bd. of Educ. (2008): Further discussion of procedural vs substantive violations
- R.E. v. New York City Dep’t of Educ. (2012): Adequacy of the IEP and retrospective testimony
- T.K. v. New York City Dep’t of Educ. (2016): Bullying as denial of FAPE
- Mr. P v. West Hartford Bd. of Educ. (2018): Inclusion and LRE
- Ventura de Paulino v. NYC DOE (2020): Pendency and reimbursement under IDEA
- H.C. v. NYC DOE (2023): Clarity in procedural and substantive obligations (or similarly recent significant cases)
Stay tuned as we explore each case in detail, enhancing your understanding and effectiveness as an advocate.