Case Analysis- Board of Education of the Hendrick Hudson Central School District v. Rowley

Case Analysis: Board of Education of the Hendrick Hudson Central School District v. Rowley

ESE603: Law and Ethics in Special Education

Case Analysis: Board of Education of the Hendrick Hudson Central School District v. Rowley

It is that time of year! Summer is over and it is time for school to start back. It can be a very exciting time, but also overwhelming for students and parents. It can be overwhelming especially if you have a child that has been diagnosed with special needs. Amy Rowley is a first grade student who is deaf. The school provided Amy with amplification system, a tutor for deaf, and speech therapy. During Amy’s Kindergarten year, a sign language interpreter was provided and Amy continued to look toward her teacher instead of using the interpreter; therefore, for first grade her teacher felt as if she did not need one. Amy’s parents feel as if she is not receiving FAPE (free appropriate public education) because the school denied having a sign language interpreter. Amy’s parents think since she is not receiving this service, she is not able to reach her full potential like her other classmates. They were disheartened and decided to take the school to court to see if they could get their daughter the proper education she deserved. First the parents need to know what FAPE is, what is covered and is not covered under FAPE, and why the court ruled in favor of the school.


Free Appropriate Public Education (FAPE) is imperative for students with disabilities and is covered under the IDEA and Section 504. Let us look at FAPE in more detail, F stands for free meaning all students with disabilities should be entitled to receive a free education at no cost to the parents or caregivers. A stands for appropriate meaning students will receive an appropriate education that is geared toward their IEP goals. They are tailored to the student’s individual needs and what is needed to help them succeed in school. P stands for public meaning that students with disabilities have the right to be educated in a public school environment. E stands for education meaning that all students have the right to receive an equal education that will help them be successful in their future (Latham, 2019). “Eligible students, ages 3 to 21 or until they graduate from high school with a regular diploma, have a right to FAPE” (GreatSchoolsStaff, 2016). However, FAPE does not mean that students will receive the best education, but an education that is appropriate to help that student succeed. FAPE is based on each individual student’s needs. There are several factors that are looked at to see if the student is receiving an appropriate education such as how well the student has done on standardized tests taken each year, how they perform in the classroom/behavior, attendance record, progress made on goals and objectives, as well as progress and report card grades (GreatSchoolsStaff, 2016).

Court Ruling

In the case of Rowley v. Board of Education of the Hendrick Hudson Central School District (1982), Amy Rowley’s parents brought a case against the school their daughter attended because they felt she was not receiving an “appropriate education” because Amy was denied a sign language interpreter to be used in the classroom. Under the IDEA, Amy is required to have a free appropriate public education based on her disability. The “free appropriate public education” required by the Act is tailored to the unique needs of the handicapped child by means of an ‘individualized educational program (IEP)” (Wrightslaw, 2019). During Amy’s Kindergarten year, the parents and the school had a meeting to discuss Amy’s needs and it was determined for her IEP that she would have an FM hearing aid, receive tutoring, and have speech therapy. The parents agreed, but still felt that she should receive a sign-language interpreter during her classes; however, this service was provided for two weeks and it was determined that it was not needed for first grade (Wrightslaw, 2019).

The court ruled that Amy was a bright child that was advancing academically better than most of her classmates that were not deaf. She interacts well with her classmates and teachers which in turn denied Amy the access to a sign language interpreter. Amy’s parents were not please and decided to present the case before the U.S. District Court where they agreed that even though Amy was advancing academically and socially, it was also determined “that she comprehends less of what is happening in the classroom than she would if she was not deaf. Which means Amy is not learning or performing as well if she did not have a hearing impairment” (Wrightlaw, 2019). This finding led the court to believe that she was not receiving FAPE which was defined by the court as “a chance to accomplish her full potential comparable to the chance given to her classmates” (Wrightslaw, 2019).

Meaningful Benefit

The term meaningful benefit in the case of Rowley v. Hendrick means “Under the Individuals with Disabilities Education Act (IDEA), public schools must provide children with disabilities a ‘free appropriate public education.’ The key mechanism by which schools meet this requirement is the individualized education program, or IEP. Each IEP must be reasonably calculated to confer an educational benefit on the child (Wrightslaw, 2019). The Court came to the conclusion that it did not have to establish a test for educational benefits because Amy was receiving specialized instruction and related services. She was performing above average in her classes” (Wrightslaw, 2019). Therefore, was Amy receiving FAPE?

For or Against?

After researching the case, I feel that Amy was not provided a free appropriate public education (FAPE) because she was denied access to a sign language interpreter. Even though it was provided for two weeks during her Kindergarten year and determined it was not needed, does not mean that she will not need it the older she gets. If Amy was provided with the services she needs, then she could benefit more by reaching her full potential. I understand that FAPE does not require the best education given, but the appropriate one, yet who is to say that by providing Amy with the interpreter would be less appropriate for her to succeed academically. If this service allowed Amy to maximize her potential and help her make even more progress throughout her academic career, then why deny her that right? (Lee, 2019).

Ruling affects Special Education Programs

The ruling of the Rowley case made the court question the meaning of FAPE? Is every student receiving the appropriate education possible? Several cases over the years have managed to question if students with disabilities are receiving the appropriate education they deserve. This led to adjustments made to IDEA. Over the years, “American educational leaders, lawmakers, and others have recognized the need to meet the educational needs of students with disabilities” (Osborne & Russo, 2014, Chapter 1, para. 3).

In conclusion, Amy Rowley’s parents were not satisfied with the school denying access to their daughter having a sign language interpreter. This case made some step back and take the time to see if students were receiving an “appropriate” education or were they just receiving “some educational benefits”? I feel that this case made a huge impact on the field of special education and should provide every educator to think about this one thought: “Are we doing everything we can to ensure that each student with or without a disability is receiving the best education possible to help them succeed in and outside the classroom?”


Educational Benefit: “Merely More Than De Minimis” or “Meaningful”? (2019). In Wrightslaw. Retrieved from

Latham, P. (2019). At a glance: Free and appropriate public education. Retrieved from

Lee, A. (2019). What Is and Isn’t Covered Under FAPE. In Retrieved from

Osborne, A. G., & Russo, C. J. (2003). Special education and the law: A guide for practitioners (3rd ed.). Thousand Oaks, CA: Corwin Press.

Special education FAQ. (2016). In Great Schools. Retrieved from

Wrightslaw. (2019). Board of Education of the Hendrick Hudson Central School District v Amy Rowley. Retrieved from

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