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Placement Decisions Requirements: The Rowley Standard

In Rowley, the United States Supreme Court provided that "implicit in the congressional purpose of providing a 'free appropriate public education' is the requirement that the education provided be sufficient to confer some educational benefit upon the handicapped child". (Board of Ed. Of the Hendrick Hudson Sch. Dist. v. Rowley, 458 U.S. 176, 201-03 (1982); J.L. v. Mercer Island Sch. Dist., 592 F.3d 938 (2009)).

The Rowley decision is widely regarded as the most looked to Supreme Court Special Education decision. It is the standard considered in all special education due process hearings. Did the program provided by or proposed by the school district rise to the level that the student in question was provided "some educational benefit". This standard is always important for attorneys and parents alike to remember. School districts are not required to provide the "Best" or "Most Appropriate" educational placement or program, but instead are required to provide only "some educational benefit". It is important to keep this in mind when choosing vocabulary at an IEP meeting for instance, instead of discussing what might be best for your child, remember to argue for what is or is not appropriate for your child.

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Navigating the road of special education law can be difficult and confusing, if you have any questions about your child's special education placement or services, Contact us by email or call us at 714-602-1498 or 866-781-7723 (toll free) for more information.

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Augustin Egelsee L.L.P.
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Anaheim Hills, CA 92808

Toll Free: 866-781-7723
Phone: 714-602-1498
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