How Is FAPE Determined? The Rowley/Endrew Test

Courts do not decide FAPE by opinion. They apply a two-part legal standard known as the Rowley/Endrew test: first, whether the school followed IDEA's required procedures, and second, whether the IEP was reasonably calculated to enable progress appropriate in light of the child's circumstances. Both parts matter, and a school can fail either one.

New to the term? Start with What is FAPE (free appropriate public education)?

Courts use a two-part legal standard (known as the Rowley/Endrew test) to determine if a school district has provided a Free Appropriate Public Education (FAPE) under IDEA.

The first question is whether the school followed all the required legal steps under IDEA when developing your child's IEP. This includes:

  • Conducting appropriate evaluations
  • Involving parents in the decision-making process
  • Writing and implementing the IEP on time

The IEP must be reasonably calculated to enable the child to make progress that is appropriate in light of their unique circumstances. This means the IEP should:

  • Be ambitious, not just a minimal effort
  • Reflect the student's unique strengths and challenges
  • Be designed to support meaningful, measurable growth

Legal Note

In Endrew F. v. Douglas County School District (2017), the U.S. Supreme Court made it clear: a child's IEP must aim for more than minimal progress. Schools must offer a plan that is tailored to help the student grow based on their individual needs.

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