Reflections on the 25th Anniversary of the U.S. Supreme Court's Decision in Board of Education v. Rowley

June 22, 2007, was the 25th anniversary of the U.S. Supreme Court’s decision in Board of Education of the Hendrick Hudson Central School District v. Rowley1 (hereafter Rowley; 1982). In Rowley, the Supreme Court interpreted Congressional intent in requiring that public schools provide a free appropriate public education (FAPE) to students with disabilities under the Individuals with Disabilities Education Act (IDEA). This ruling— which is arguably the most important special education decision by the high court—has had a profound effect on the education of students with disabilities. In this article we reflect on the importance of this decision and discuss how changes in IDEA in the 1997 and 2004 reauthorizations have changed the definition of a FAPE. First, we briefly review passage of the Education of All Handicapped Children Act2 (EAHCA) in 1975. Second, we examine the facts of the Rowley case and the Supreme Court’s ruling. Third, we look at some court cases following Rowley, which interpreted the meaning of the Supreme Court’s ruling. Fourth, we consider the effects of IDEA 1997 and 2004 on the meaning of FAPE. Finally, we discuss principles that school districts should follow when developing individualized education programs (IEPs) that provide a FAPE for students with disabilities.