A student was enrolled in a public school, where he qualified for special education services due to a diagnosis of autism. He demonstrated behavioral challenges, such as screaming in class, climbing on furniture and other students, and occasionally running away from school. His parents believed he was not making any progress and pulled him out of public school when the district created an IEP for the next school year that the parents regarded as “more of the same.” They enrolled him in a private school and filed a lawsuit against the school district, alleging that it had failed to provide the student with a free and appropriate public education as required by the Individuals with Disabilities Education Act and seeking reimbursement for the tuition from the school district.

The issue in the case was what standard to apply to determine what kind of “educational benefit” is required by the IDEA. The IDEA requires that a school must offer an IEP that is “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” Some courts had previously held that the IDEA only requires educational benefits that are just slightly more than minimal. In this case, the court initially found that the school only needed to provide an IEP that provided a minimal benefit to the child’s educational progress. The parents appealed that decision and it was eventually considered by the United States Supreme Court.

The Supreme Court unanimously held that the IDEA requires that a child’s IEP must be designed to provide more than a minimal benefit and returned the case to the lower courts to apply a tougher standard. In doing so, the justices stated that schools must provide a program that is “appropriately ambitious in light of the child’s circumstances” and explicitly found that this standard is much more demanding than the minimal standard applied by the lower court. In the opinion, Chief Justice John Roberts said that “the goals may differ … but every child should have the chance to meet challenging objectives” and that, with regards to the “minimal progress” standard, “receiving an instruction that aims so low would be tantamount to sitting idly … awaiting the time when they were old enough to drop out.” The Court then went on to say that the IDEA demands more.