Under Construction
Cases Every Parent Advocate Should Know
These cases have shaped how schools, courts, and agencies interpret disability rights, special education, parental participation, and access to education. Some apply nationwide. Others are especially important in Hawaiʻi and the Ninth Circuit.
Hawaiʻi / Ninth Circuit Cases
Doug C. v. Hawaiʻi Dep’t of Educ., 720 F.3d 1038 (9th Cir. 2013)
Why it matters
This is one of the most important special education cases from Hawaiʻi. The Ninth Circuit held that the IDEA’s parental participation requirements are central to the IEP process, and a school district may violate the IDEA by holding an IEP meeting without a parent who is actively trying to participate.
A district cannot simply move forward because of scheduling pressure if the parent has not refused to participate and is making efforts to attend.
Parent takeaway
Parent participation is not a formality. It is a legal right.
PAU keywords
- Parent participation
- IEP meetings
- FAPE
- Procedural violations
- Hawaiʻi landmark case
Nationwide IDEA Cases
Board of Education of the Hendrick Hudson Central School District v. Rowley, 458 U.S. 176 (1982)
Why it matters
This was the Supreme Court’s first major IDEA/FAPE case. The Court held that an IEP must be reasonably calculated to enable the child to receive educational benefits. The IDEA does not require the best possible education or a program that maximizes the child’s potential.
Parent takeaway
Schools often cite Rowley when discussing FAPE, but Rowley does not mean “anything goes.” It requires an individualized educational program that provides educational benefit.
PAU keywords
- FAPE
- Educational benefit
- IDEA foundations
Endrew F. ex rel. Joseph F. v. Douglas County School District RE-1, 580 U.S. 386 (2017)
Why it matters
The Supreme Court strengthened the FAPE standard. The Court held that a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.
The Court rejected the idea that an IEP is adequate if it produces only trivial or minimal progress.
Landmark quote
“A reviewing court may fairly expect those authorities to be able to offer a cogent and responsive explanation for their decisions that shows the IEP is reasonably calculated to enable the child to make progress appropriate in light of his circumstances.”
Parent takeaway
Schools should be able to explain:
- why a service is being provided,
- why a service is being denied,
- what data was considered,
- how proposed supports will help the student make progress, and
- why the program is appropriate for that child.
Why parents reference this case
Endrew F. is frequently cited in disputes involving:
- evaluations
- eligibility decisions
- prior written notices
- service reductions
- placement decisions
- IEP development
- progress monitoring
Key principle
Schools must be able to provide a reasoned explanation for decisions affecting a student’s education.
Honig v. Doe, 484 U.S. 305 (1988)
Why it matters
The Supreme Court recognized important protections for students with disabilities in school discipline matters. Schools cannot simply remove a student because behavior is disability-related without following the IDEA’s procedural protections.
Parent takeaway
Schools cannot push a student out simply because the disability creates behavioral challenges.
Section 504 / ADA Cases
Southeastern Community College v. Davis, 442 U.S. 397 (1979)
Why it matters
One of the earliest Section 504 cases. The Court held that disability discrimination law requires meaningful access, but it does not require an institution to make fundamental or substantial changes to its program.
Parent takeaway
Section 504 requires access, but not every requested modification is required.
Alexander v. Choate, 469 U.S. 287 (1985)
Why it matters
The Supreme Court recognized that discrimination can occur even when a policy is neutral on its face. Section 504 can reach barriers that deny meaningful access.
Parent takeaway
Equal treatment is not always equal access.
Fry v. Napoleon Community Schools, 580 U.S. 154 (2017)
Why it matters
The Supreme Court clarified when families must exhaust IDEA procedures before bringing ADA or Section 504 claims. The key question is whether the gravamen of the complaint is the denial of FAPE.
Parent takeaway
Not every disability-rights claim has to go through special education due process first.
Perez v. Sturgis Public Schools, 598 U.S. 142 (2023)
Why it matters
The Supreme Court held that a family may pursue ADA or Section 504 claims for remedies the IDEA cannot provide, such as compensatory damages, without completing IDEA exhaustion first.
Parent takeaway
The IDEA is not always the only path.
A.J.T. v. Osseo Area Schools, 605 U.S. ___ (2025)
Why it matters
This case is important for disability discrimination claims under Section 504 and the ADA, but I would verify the official reporter citation before publishing it. If you want to include it, the statement should be carefully checked against the final Supreme Court opinion.
Parent takeaway
Some courts have imposed extra hurdles in disability discrimination cases; this case may affect that analysis, but the exact scope should be confirmed before use.
Disability Harassment / Bullying
Davis v. Monroe County Board of Education, 526 U.S. 629 (1999)
Why it matters
The Supreme Court held under Title IX that a school may be liable when it is deliberately indifferent to known, severe, and pervasive harassment in a federally funded educational program.
Although this is a Title IX case, courts often look to it in discussing harassment claims involving students with disabilities.
Parent takeaway
A school cannot know about serious harassment and do nothing.
Doug C. v. Hawaiʻi Dep’t of Educ.: Schools must make genuine efforts to include parents in IEP meetings; they cannot ignore parent participation just to meet deadlines.
Rowley: Schools must provide an IEP reasonably calculated to provide educational benefit.
Endrew F.: The IEP must be reasonably calculated to enable appropriate progress in light of the child’s circumstances.
Honig v. Doe: Disability-related behavior cannot be used to bypass IDEA protections.
Southeastern Community College v. Davis: Section 504 requires meaningful access, not fundamental alterations.
Alexander v. Choate: Neutral policies can still deny meaningful access.
Fry v. Napoleon Community Schools: Some disability-rights claims can proceed without IDEA exhaustion.
Perez v. Sturgis Public Schools: Plaintiffs may seek damages under ADA/Section 504 without exhausting IDEA when IDEA cannot provide that remedy.
Davis v. Monroe County Board of Education: Schools may be liable for deliberate indifference to severe harassment.
References
1.
Q&A on Endrew F. v. Douglas County School District
U.S. Department of Education · n/a · 2017
2.
N.Y. Law School Law Review · 63 N.Y.L. Sch. L. Rev. 29 · 2018
3.
Doug C. v. Hawaii Dep’t of Educ.
9th Cir. · n/a · 2013
4.
Revisiting the FAPE Standard from Rowley and Endrew F.
Idaho State Department of Education · n/a · 2022
5.
Doug C. v. State of Hawaii Dep’t of Educ.
9th Cir. · n/a · 2013
6.
Endrew F. v. Douglas County School District Re-1
U.S. Supreme Court · 580 U.S. 386 · 2017
7.
U.S. Supreme Court · 458 U.S. 176 · 1982

