Board of Education v. Rowley (1982)
- Sam Shepherd
- Sep 23, 2024
- 5 min read
Updated: Jul 24
By Nicole Tursellino
Overview
Board of Education of the Hendrick Hudson Central School District v. Rowley, 458 U.S. 176 (1982) was a case centered around the understanding of the Education Act for All Handicapped Children Act of 1975 that questioned whether or not public schools that received federal funding from the state were required to personally assist every student in their special education program with a personalized mentor to allow the individual to reach their full academic potential. The Supreme Court upheld in a 6-3 decision produced by Justice William H. Rehnquist stated that schools are not required to provide special services to an individual student with special needs when that individual is otherwise receiving an adequate education and other forms of personalized instruction that further the academic development of the individual.
Summary
In 1982, a case presented itself where Amy Rowley, a deaf student attending Furnace Woods School (a public school), was denied access to having a sign language interpreter, as she was progressing well as a student without the interpreter. Amy had been using her lip-reading skills in the classroom setting; she also had minimal residual hearing. While she was provided a hearing aid, the presence of an interpreter continued to not be provided. After Furnace Woods School refused Amy the interpreter, her parents sued the school stating that there was a violation of the Education of All Handicapped Children Act of 1975. This Act demonstrates that if a school is receiving federal funding, then the school is required to provide a “free appropriate public education” to individuals that possess a disability.
When the case entered into the District Court, the court found that Amy Rowley and her family were in the right, highlighting the ways in which Amy was not being granted the opportunity in school to be her best self and reach her full academic potential. With the lack of the interpreter, the publicly funded school was found to have violated the Education of All Handicapped Children Act of 1975. The Court of Appeals also favored Amy Rowley, highlighting that by means of the Act, handicapped individuals should be provided the resources to achieve the same level of academic achievement and quality of education as their peers who did not have disabilities. However, the Supreme Court did not interpret the Act to be interpreted in this way, reversing the decisions made within both lower courts and found in a 6 to 3 decision, produced by Justice William H. Renquist, for the Board of Education of Hendrick Hudson Central School District, Westchester City, that the school did not have to provide Ms. Rowley with a sign language interpreter. The Supreme Court interpreted the Education of All Handicapped Children Act of 1975 to be that schools had full discretion over what they felt about which services were to be administered to handicapped individuals, and thus, that the school district was permitted to deny services to Amy Rowley in the fact that she was receiving an adequate education and receiving personal instruction in other capacities. Thus, schools are the entities that can determine what best suits its handicapped students' individual needs in an academic environment. In the Court's decision, the Court interpreted what is required of the “free and appropriate public education” (FAPE) clause of the Education of All Handicapped Children Act of 1975.
Impact
Board of Education of the Hendrick Hudson Central School District v. Rowley, 458 U.S. 176 (1982) was the first case that entered the Supreme Court’s docket that highlighted the interpretation of the Education of All Handicapped Children Act of 1975. In doing so, the Supreme Court found that publicly funded schools, while required to make accommodations for students with a handicap, did not have to provide every service necessary. In doing so, the Court demonstrated the meaning of “free and appropriate public education” and set the leading precedent for all cases that further needed the Court's opinion in determining whether a violation of the Education of All Handicapped Children Act of 1975 occurred.
In 1990, the Education of All Handicapped Children Act of 1975 became known as the Individuals with Disabilities Education Act (IDEA). After the ruling of the Court in 1982, the Supreme Court had other cases enter its docket years later, where they turned to the precedent upheld in Rowley and its interpretation of the, now, Individuals with Disabilities Education Act, in making its decision. Most notably, Endrew F. v. Douglas County School District RE-1, 580 U.S. __ (2017), turned to the ruling upheld in Rowley in finding that schools are required to provide students with the means necessary to receive an adequate education, ensuring that the student is receiving assistance in making academic progress in a way that is most appropriate for them. Rowley shed light on what “appropriate progress” looked like when a student possessed a disability; however, it “did not provide concrete guidance with respect to a child who is not fully integrated in the regular classroom and not able to achieve on grade level.” When the Court ruled in a unanimous decision for Endrew F. in Endrew F. v. Douglas County School District, the Court found that schools need to provide each student in a public school’s disability program with an IEP (Individualized Education Program) to ensure that the students are making the necessary progress they individually can achieve.
Rowley set the legal precedent in interpreting the laws related to the educational needs of individuals with developmental disabilities, and the ways in which public schools can support students' academic growth. In doing this, it helps clarify the understanding behind “free and adequate public education,” and essentially establishes what falls into this category.
Additional Documents
To listen to the Oral Argument made on March 23, 1982, click here:
To read the Opinions and Dissents of the case, click here:
For more information about the Education for All Handicapped Children Act of 1975, click here:
For more information about the Individuals with Disabilities Education Act (IDEA), click here:
To learn more about Endrew F. v. Douglas County School District RE-1, 580 U.S. __ (2017), click here:
Citations
"Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley." Oyez, www.oyez.org/cases/1981/80-1002. Accessed 19 Sep. 2024.
“BOARD of EDUCATION of the HENDRICK HUDSON CENTRAL SCHOOL DISTRICT BD. OF ED., WESTCHESTER COUNTY, et Al., Petitioners v. Amy ROWLEY, by Her Parents and Natural Guardians, Clifford and Nancy Rowley Etc.” LII / Legal Information Institute, 2019, www.law.cornell.edu/supremecourt/text/458/176.
“Endrew F. V. Douglas County School District RE–1, 580 U.S. ___ (2017).” Justia Law, supreme.justia.com/cases/federal/us/580/15-827/#tab-opinion-3706582.
Idaho State Department of Education. The Rowley Case: What Does It Really Mean? Nov. 2022, www.sde.idaho.gov/sped/sped-manual/files/chapters/chapter-2-free-and-appropriate-public-education/The-Rowley-Case.pdf.
Smith, Christina (Kirsty). “Lawrence Blair Smith.” Veterinary Record, vol. 183, no. 23, Dec. 2018, pp. 700–0, https://doi.org/10.1136/vr.k5282.