The Rowley case concerned a hearing-impaired girl named Amy Rowley who was a student at the Furnace Woods School in Hendrick Hudson Central School District, Peekskill, N.Y. Amy had minimal residual hearing and was an excellent lip reader. During the year before she began attending school, a meeting between her parents and the school administrator resulted in a decision to place her in a regular kindergarten class. Several administrators prepared for Amy’s arrival by attending a course in sign language interpretation, and a teletype machine was installed in the principal’s office to facilitate communication with her parents, who were also deaf. At the end of the trial placement, it was determined that Amy should remain in the kindergarten class but that she should be provided with an FM transmitter. Amy successfully completed her kindergarten year, but her parents argued that she was not maximizing her educational benefit. They believed the FAPE requirement under the IDEA protected such a right. The Supreme Court sided with the school, determining that “some educational benefit” was required by FAPE and that the bar had been met. This landmark decision set a low standard for special educators from 1982-2017, when the Endrew F. case increased the bar for FAPE.
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