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ERIC Number: EJ1156714
Record Type: Journal
Publication Date: 2017-Oct
Pages: 3
Abstractor: ERIC
ISSN: ISSN-0164-775X
"Endrew F. v. Douglas County School District": Implications for Teams Serving Students with Autism Spectrum Disorder
McKenney, Elizabeth L. W.
Communique, v46 n2 p11-12, 14 Oct 2017
On March 22, 2017, the Supreme Court unanimously ruled that schools are obligated to provide more than de mimimus services for students with disabilities. The core issue in "Endrew F. v. Douglas County Schools" is how schools are to define the "A" in FAPE: What is an appropriate public education? Douglas County schools held that they were upholding their legal responsibility in providing de minimus benefit to Endrew, as that was their interpretation of the precedent-setting case previously litigated around this issue ("Rowley v. Board of Education"). However, the current court disagreed, determining that "Rowley" spoke to the issue of what is appropriate in the case of a child who was succeeding in the general education setting with accommodations, whereas the issue in the "Endrew" case is the nature of FAPE when a student is demonstrating little to no progress year upon year, despite having an IEP. Furthermore, Endrew F.'s parents argued that IEP-based services should be designed to enable achievement and a level of independence that is "substantially equal" to those provided to students without disabilities, but the Court did not uphold this high standard, referring to the "Rowley" precedent, in which it was determined that such a standard would be impossible to measure and, therefore, impossible to enforce. For those familiar with the needs of students with autism spectrum disorder (ASD), and especially those who have worked with students with ASD during the early education and elementary school period, it is perhaps not surprising that this issue (defining FAPE for students with intensive needs) arose around a child with ASD. The purpose of this article is to examine the unique features of ASD that make issues like the ones raised in the "Endrew" likely to affect other students and their educational teams, and to discuss the possible ramifications of the "Endrew" decision. Particular attention is given to the way in which school psychological services can be affected by, and can affect, the sometimes difficult process of implementing appropriate educational services for students with ASD. Specifically, the article addresses four factors that influence students with ASD and their educational teams: patterns of variable and unpredictable development, education in the least restrictive environment, patterns of adaptive skill development, and collaboration with families.
National Association of School Psychologists. 4340 East West Highway Suite 402, Bethesda, MD 20814. Tel: 301-657-0270; Fax: 301-657-0275; e-mail:; Web site:
Publication Type: Journal Articles; Reports - Evaluative
Education Level: N/A
Audience: N/A
Language: English
Sponsor: N/A
Authoring Institution: N/A
Identifiers - Location: Colorado
Grant or Contract Numbers: N/A