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Progress in special education

Endrew F. v. Douglas County School Dist. RE–1

Updated Oct 18, 2026

In brief

The Supreme Court wiped out the appeals court’s ruling and sent Endrew F.’s case back, without deciding how much educational progress his school had to provide.

Where it stands
Decided

Decided 8-0 · March 22, 2017 · Opinion by Chief Justice Roberts

What it’s about
Endrew F.’s case concerned what level of educational progress school districts must plan for children with disabilities under the IDEA.
Who it affects
The Tenth Circuit’s ruling no longer stands, and Endrew F.’s case returns to that court; the Supreme Court did not decide what educational benefit was required for him.

Summary: written with AI from the case record.

Illustration for Endrew F. v. Douglas County School Dist. RE–1
Conceptual illustration · AI-generated

What it's about

The Supreme Court wiped out the appeals court’s ruling (vacated it) and sent the case back to the lower court (remanded it); this procedural action did not decide that question in this case.

The IDEA promises children with disabilities a free appropriate public education; this dispute focused on how much progress a school plan must support.

Question presented

What is the level of educational benefit that school districts must confer on children with disabilities to provide them with the free appropriate public education guaranteed by the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq?

What the Court decided

Holding

To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances. 798 F. 3d 1329, vacated and remanded.

Result
Vacated

The vote

  • Joined the judgment
  • Wrote an opinion
Majority · 8joined the Court's opinion
  1. Breyer
  2. Kagan
  3. Thomas
  4. Kennedy
  5. Ginsburg
  6. Sotomayor
  7. Robertswrote the opinion
  8. Alito
8 justices joined the judgment.

What's next

The case returns to the Tenth Circuit for another look.

Documents

2

Docket activity

10
  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Impact Analysis

    Oct 18, 2026 · Generated

  • AI analysis generated: Opinion Summary

    Oct 18, 2026 · Generated

  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 18, 2026 · Generated

Show 5 more
  • AI analysis generated: Decision Record

    Oct 18, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Oct 18, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 18, 2026 · Court records

  • Opinion added: Opinion

    Mar 22, 2017 · Court records

  • Brief added: Questions Presented

    Court records

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Oct 18, 2026Methodology

Court records and filings

Reporting and analysis