Appropriate Education and Rowley

Abstract

Abstract: The Education of the Handicapped Act requires state and local educational agencies to provide a free, appropriate public education to all children with disabilities. The meaning of "appropriate" was left quite open-ended by Congress, which predicated "appropriateness" on compliance with state standards and a child's IEP. The Supreme Court's first special education case, Board v. Rowley (1982), clarified the meaning of "appropriate"—as did the Court's later decision, Irving I.S.D. v. Tatro (1984J—but raised questions about just how far the EHA requires schools to go in educating a child. This article analyzes Rowley's meaning for "appropriate" education and justifies the Tightness of that decision in terms of its impact on the education of the child and the integration of children who have disabilities with children who do not.