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)).