In rejecting the notion that an Individualized Education Program (IEP) need only be reasonably calculated to allow the student to make “merely more than de minimis progress”, the Supreme Court in Endrew F. v. Douglas County School District RE-1. determined that a “free appropriate public education” is delivered, pursuant to the IDEA, if “an educational program [is] reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances”. To hold otherwise would allow children with disabilities to “receiv[e] instruction that aims so low [such that they would be] sitting idly . . . awaiting the time when they were old enough to drop out”.
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