Court Decisions Addressing Related Services

Court decisions have played an important role in shaping how related services are provided in special education. Over the years, several important court decisions have helped clarify how related services should be provided and what students are entitled to.
One of the most important Supreme Court cases related to special education is Board of Education of Hendrick Hudson Central School District v. Rowley (1982). While it did not directly address related services, it set the stage for understanding that related services, such as speech therapy or interpreters, must be provided if they are necessary for the student to access their education.
The case involved a student, Amy Rowley, who was deaf. Her parents argued that the school was not providing her with an adequate education because it didn’t offer her a sign language interpreter, even though she was doing well academically. The Supreme Court ruled that IDEA requires schools to provide a “free appropriate public education” (FAPE) but does not guarantee services that would maximize a student’s potential. The ruling emphasized that schools must provide services that allow students with disabilities to access the general education curriculum, but they are not required to provide services that go beyond what is necessary to benefit from education.
Endrew F. v. Douglas County School District (2017) is a more recent and significant Supreme Court case that clarified the standard for providing FAPE under IDEA. Endrew F. was a student with autism, and his parents believed that the school district’s IEP did not provide enough support for him to make meaningful progress. The Court ruled that under IDEA, a school must offer an IEP that is “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” This ruling emphasized that the IEP must be tailored to the individual child’s needs, including the provision of necessary related services. For example, if a student needs speech therapy or counseling to progress in school, those services must be provided in a way that helps the student make “meaningful progress”, not just minimal progress. This case set a higher standard for what is considered an appropriate education and related services.
In Forest Grove School District v. T.A. (2009), the Supreme Court addressed whether a student could receive reimbursement for private school tuition if the public school failed to provide the necessary related services. T.A., a student with disabilities, was not making adequate progress in his public school, so his parents placed him in a private school that provided the services he needed, including specialized therapy. The Court ruled in favor of T.A., allowing his parents to be reimbursed for the cost of private school tuition. This decision showed that if a public school fails to provide the required related services, parents have the right to seek alternative services and may be entitled to reimbursement for those services.
The 3rd Circuit (the region that includes New Jersey, Pennsylvania, and Delaware) has had several important court cases involving related services in special education.
In R.R. v. New Jersey, a New Jersey court reviewed a situation where the parents of a student with disabilities (R.R) felt their child was not receiving all the related services they were entitled to. R.R was not making the expected progress in school because his school was not providing the necessary services. The court decided that the school had to follow the law and ensure that R.R. received all the related services mentioned in his Individualized Education Plan (IEP). This ruling showed that schools must provide all the services listed in a student’s IEP. If a school fails to do so, the parents can the court to review to make sure the school is meeting its legal obligations.
In L.E. v. Ramsey School District, the 3rd Circuit Court of Appeals considered a case in which a student with L.E., a student with significant learning and physical disabilities, was not receiving enough services to meet her needs. The court ruled that the school district did not offer a sufficient amount of related services. The court said that the school had to make adjustments to provide the right amount of support, including physical therapy, so that the student could benefit from her education. This case confirmed that schools must provide the services necessary for students with disabilities to fully access their education, based on the individual needs of each student. The court emphasized that related services must be determined by what is required to help a student make progress and meet their educational goals.
These cases have clarified that schools must provide services that allow students with disabilities to access education and make meaningful progress. The courts have also emphasized the importance of individualized services based on a student’s unique needs, including services like speech therapy, counseling, and more. As special education laws continue to evolve, court cases will likely keep influencing how related services are delivered to ensure that all students with disabilities receive the support they need to succeed in school.