page_title: Board of Education of the Hendrick Hudson Central School District v. Rowley
section_title: Opinion of the Court
hierarchical_section_title: Board of Education of the Hendrick Hudson Central School District v. Rowley / Supreme Court / Opinion of the Court
context_page_description: Board of Education of the Hendrick Hudson Central School District v. Rowley, 458 U.S. 176, is a United States Supreme Court case concerning the interpretation of the Education for All Handicapped Children Act of 1975. Amy Rowley was a deaf student, whose school refused to provide a sign language interpreter. Her parents filed suit contending violation of the Education for All Handicapped Children Act of 1975. In a 6-3 decision authored by Justice Rehnquist, the Court held that public schools are not required by law to provide sign language interpreters to deaf students who are otherwise receiving an equal and adequate education.
context_section_description: On June 28, 1982 the Court handed down a 6-3 decision in favor of the petitioners. Justice William Rehnquist wrote for the majority, with Justice Byron White writing the principle dissent joined by Justices William Brennan, Jr. and Thurgood Marshall. The Court answered two questions: "what is meant by the Act's requirement of a 'free appropriate public education'? And what is the role of state and federal courts in exercising the review granted by 20 U.S.C. § 1415?"
  The Court held that both District and Appeals Courts were wrong in their contention that the intent of the law was to provide for handicapped children's full potentials but rather to simply give them access. They specifically overruled the District Court's finding that "The Act itself does not define 'appropriate education'", with Justice Rehnquist quoting the text of the statute itself: "The term 'free appropriate public education' means special education and related services" followed by further definitions of those terms. Instead, the text of the legislation and the legislative intent show that the purpose of the law was not to allow each child to achieve their full potential, but to simply provide sufficient resources for handicapped children to access education. Rehnquist pointed to the text of the Act creating a prioritization of how resources are to be allocated: "States receiving money under the Act must provide education to the handicapped by priority, first "to handicapped children who are not receiving an education" and second "to handicapped children ... with the most severe handicaps who are receiving an inadequate education." In his concurrence, Justice Blackmun disagreed with the majority's finding of legislative intent, quoting his previous concurrence in Pennhurst State School v. Halderman: "it seems plain to me that Congress, in enacting this statute, intended to do more than merely set out politically self-serving but essentially meaningless language about what the handicapped deserve at the hands of state authorities." He agreed with the final judgement of the Court, however, as he, like the majority, believed the District Court should not have prescribed its own remedy but "should have given greater deference than they did to the findings of the School District's impartial hearing officer and the State's Commissioner of Education".
  They next tackled the question of the role of the Courts in the judicial review process. Under the Act, parents are provided a civil cause of action in courts when other administrative appeals are exhausted. The Court rejected the petitioners' contention that this right to judicial review only applied to procedural review of the administrative appeals and whether the decision was based on sufficient evidence. However they likewise stopped short of the de novo review that the Rowleys had advocated for which would allow the courts to prescribe particular educational methods like the District Court had. Rather, the majority held that a court must assess two question: "First, has the State complied with the procedures set forth in the Act? And second, is the individualized educational program developed through the Act's procedures reasonably calculated to enable the child to receive educational benefits? If these requirements are met, the State has complied with the obligations imposed by Congress, and the courts can require no more."  Quoting San Antonio Independent School District v. Rodriguez, the Court reiterated that the judicial branch lacks the expertise "to resolve persistent and difficult questions of educational policy."
caption: Justice William Rehnquist wrote for the majority.
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