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The goal of this article is to assist individualized education program (IEP) team personnel to not make errors in the placement of students. To do so the authors: (1) describe what a placement decision is and who makes the decision; (2) review the placement requirements of the Individuals With Disabilities Education Act (IDEA, 2006); (3) examine guidelines from the seminal cases that have addressed placement issues; (4) describe how IEP teams can avoid the most common placement errors; (5) provide a placement flowchart to help IEP teams make legally sound placement decisions; and (6) offer principles to help IEP teams make legally sound placement decisions.

This article concludes this special issue by highlighting some of the most important points from the U.S. Supreme Courts decision in "Board of Education v. Rowley" (1982) and "Endrew F. v. Douglas County School District" (2017) but also discussing another crucial point to which school district personnel must adhere to ensure that a free appropriate public education (FAPE) is provided: ensuring a student's individualized education program (IEP) is being implementing as written.

This article begins with a scenario depicting the difficulties encountered by a young student in the Douglas County School District in Castle Rock, Colorado, named Endrew (called Drew by his parents). This situation, which began at Drew's individualized education program (IEP) meeting at Summit Ridge Elementary School when he was in fourth grade, led to a due-process hearing and two federal court cases and eventually resulted in the seminal ruling by the U.S. Supreme Court in "Endrew F. v. Douglas County School District" (or "Endrew F."; 2017). The ruling, which was written by chief justice John Roberts, defined the educational-benefit standard that school districts must meet in developing a free appropriate public education (FAPE) for students with disabilities who receive special education services under the IDEA. Following the high court's ruling, the case went back through the two lower federal courts that first heard the case. A few months after the Supreme Court's ruling, the authors published an article in "TEACHING Exceptional Children" in which they reviewed the decision and provided implications for special educators for implementing programs that meet the FAPE standard of the the Individuals With Disabilities Education Act (IDEA, 2006) (see EJ1160170). The purpose of this article is to provide an update of that article and to examine the effects of the "Endrew F." ruling 3 years after it was announced. To accomplish this, the authors (1) review the definition of FAPE in the IDEA; (2) reexamine and update the Supreme Court's decision in "Endrew F."; and (3) extrapolate principles for educators from "Endrew F." with respect to development of students' IEPs.

This article begins by describing a scenario in which a fourth-grade learning disabled student's individualized education program (IEP) team came together to develop his IEP and in so doing made a number of procedural and substantive errors. The purpose of this article is to examine the procedural and substantive requirements of the Individuals With Disabilities Education Act (IDEA, 2006) with the goal of helping school personnel avoid making procedural and substantive errors when developing students' IEPs.

The purpose of this article is to examine the free appropriate public education (FAPE) requirements of the Individuals With Disabilities Education Act (IDEA). The authors first briefly examine the definition of FAPE in the IDEA. Second, they delve into the U.S. Supreme Court's decisions in "Board of Education v. Rowley" and "Endrew F. v. Douglas" and how these decisions have affected the definition of FAPE. They next address the procedural, substantive, and implementation errors school district personnel often make when developing students' special education programs. They offer suggestions on how faculty members can prepare their preservice teachers to understand and avoid these errors and develop educationally meaningful and legally correct special education programs that confer a FAPE.

The role of the principal is very complex. Principals are the leader of the building and all the education that occurs within its walls. Included in the responsibilities for principals is the education of students with disabilities. A principal needs to have solid, fundamental knowledge of the scope of special education and the processes used for evaluating and educating students protected under the Individuals With Disabilities Education Act (IDEA). Realizing principals need to know about special education, this paper reviews recommendations from multiple studies related to special education competencies for principals, and will also review suggestions from experts in the field. Based on the recommendations for principal's knowledge about special education, it will review the standards for principals' training provided by multiple organizations specifically as it relates to special education. The organizations and their recommendations related to principal training will be reviewed by the National Council for Accreditation of Teacher Education (NCATE), the Teacher Education Accreditation Council (TEAC), the Council for the Accreditation of Educator Preparation (CAEP), the Interstate School Leaders Licensure Consortium (ISLLC), the National Policy Board for Educational Administration (NPBEA), along with recommendations of the National Association of Elementary School Principals (NAESP), and the National Association of Secondary School Principals (NASSP). Finally, it will propose a specific set of special education competencies for principals based on recommendations from hundreds of principals across the nation.

Thirty-five years ago, the U.S. Supreme Court announced its decision in "Rowley" (1982). The case, which was the first special education case to be heard by the Court, ruled on the question of what constituted Free Appropriate Public Education (FAPE) for students with disabilities under the Education for All Handicapped Children Act of 1975 (EAHCA), which was retitled as IDEA in 1990. On March 22, 2017, the U.S. Supreme Court announced its decision in "Endrew F.," which also addressed FAPE. These two cases should be read in tandem, as they are extremely important in providing special educators with guidance regarding what is an appropriate education for students with disabilities. This article defines IDEA's FAPE Requirement. It reviews the Supreme Court's first FAPE ruling in "Rowley." It then describes FAPE rulings by the U.S. Circuit Courts of Appeals and how the circuit courts differed in their interpretations of the "Rowley" decision. The authors then present the history of the "Endrew F." case, the oral arguments before the Supreme Court, and the Court's unanimous ruling in this case. A discussion of implications of the decision for special education follows. A list of the top 10 implications from "Endrew F." is provided.

There is little question that today's society is a litigious one, and few professions can escape the realities of such. Although there is no mandate for national data collection on special education due process hearings (Ahearn, 2002), Chambers, Harr, and Dhanani (2003) estimate that more than 9,000 requests for dispute resolution are made per year. The hearings that result from unresolved disputes between parents and school district personnel are often stressful (Lombardi & Ludlow, 2004; O'Shea, Bateman, Algozzine, & O'Shea, 2004), and the outcomes are frequently disappointing to both parties (Mills & Duff-Mallams, 2004; Vitello, 1990). In this article, the authors attempt to broaden discussion about due process by pointing out potential benefits frequently overlooked in practice and in the professional literature. They begin by offering a redacted or summarized version of a due process case as example. They present reasons why education professionals should view due process hearings as instructive, and then they follow up with suggestions about how educators can best use legal reviews of decision summaries. (Contains 4 tables.)

This article presents a due process hearing case study of a mother who contended that his son, D.J., has been denied of a free and appropriate public education (FAPE) of his School District after being suspended from school. D.J., an elementary student, had been described as hyperactive, inattentive, defiant, and often volatile. He was identified by the school counselor as having "a behavior problems so out of control that his presence threatened the safety of the other students." After a particularly violent incident that sent D.J. and another boy to the hospital, D.J. was suspended. His mother argued that the District failed to evaluate and program appropriately her son's behavioral and learning disabilities and that it restricted his access to education for an excessive period. The District contended that suspending D.J. was justifiable, and that a suitable alternative school for D.J. had been identified, but the mother failed to cooperate. However, after a thorough study, the hearing officer determined that it was clearly a denial of FAPE; the student is entitled to compensatory education equal to the period of deprivation.

Marnie is a resident of an unnamed School District ("the District"). In January 2000 at the age of 13, Marnie was involved in a bicycle accident that severely damaged her central nervous system, leaving her without use of her legs or left hand and cognitively impaired. She had not received special education previously. By September 2001, Marnie had returned home and began receiving instruction in daily living skills. In February 2002, Marnie joined the District's class for students with learning disabilities to receive instruction that was more academic. In March 2002, when Marnie was 15, the transition portion of her individualized education program (IEP) contained a few entries--she was to follow directions, come to class on time, and ask for help when needed--but not much else. In January 2003, Marnie began attending a local vocational technical program three mornings a week, where she learned to sort nuts and bolts and package pretzels. Her individualized education program (IEP) did not list outcomes for postsecondary training, employment, or residential program. During the 2003-2004 school year, Marnie was enrolled in an academic curriculum, and her IEP did mention community living and instruction for postschool outcomes. Throughout the school year she continued instruction in a self-contained classroom that focused on basic academics letter and number recognition, simple computation, safety words). In August 2004, her program was changed from an academic focus to a prevocational/vocational focus. In June 2005, the District tried to graduate Marnie. Marnie's parents filed for a due process hearing, citing two specific issues: the transition plan was inappropriate and the District's attempt to graduate Marnie was also inappropriate, thereby denying her a free appropriate public education (FAPE). The filing of the hearing prior to the graduation ceremonies prevented Marnie from participating in graduation. She continued to receive special education services throughout summer 2005, during which time the hearing was held in five sessions. The hearing officer found that the District's attempt to graduate Marnie was clearly inappropriate. The decision directed that she be allowed to stay in school through age 21 in order to receive the transition services necessary for her to receive a free appropriate public education.

Greg is 13 years old, and currently in seventh grade; he entered an unnamed District ("the District") school in fourth grade as a student with a specific learning disability; he had been identified as eligible for special education programming and services during second grade. During fifth and sixth grade Greg was provided services through a resource teacher for his learning disabilities, most notably for his problems with language arts and math. During sixth grade his behavioral difficulties resulted in him spending the last 6 weeks of the school year in an alternative education placement. Because of his behavior difficulties, the District sought to classify Greg as emotionally disturbed and sought a placement other than the resource room for students with learning disabilities. The issue presented at the due process hearing was the appropriateness of the District's proposed placement in a full-time classroom for students with emotional disturbance. Greg's parents opposed the proposed placement, wanting him retained in his neighborhood school with additional support. This article discusses the history of Greg's case and the decision made by the court.

"Kevin" is a 16-year-old student identified by an unnamed School District ("the District") as a student with a learning disability; he is also eligible for a Section 504 plan as a student with ADHD. He currently attends his local high school. He and his friends were in the hall of his high school when Kevin, on a dare from his friends, dropped his pants and "mooned" some other students. His science teacher happened to walk around the corner at that very moment, and implored him to pull up his pants. He later said he did not hear the science teacher because of the other students' noise; the science teacher believed Kevin intentionally was not following directions, and kept his pants down to offend her. As a result, Kevin was suspended for 10 school days. In contemplation of possibly removing him for additional days, the District convened a manifestation determination meeting wherein they found that his actions were not a manifestation of his specific learning disability in math. Kevin's parents disagreed with the manifestation determination report as completed by the District, and requested a due process hearing to determine if the behavior was a manifestation of his disability. The fundamental issue for the parents in this case was whether Kevin's behavior was a manifestation of his attention deficit/hyperactivity disorder (ADHD). The parents alleged the district failed to (a) recognize Kevin's extensive history of behavior problems associated with his ADHD, and (b) convene an appropriate team to make the manifestation determination. The Hearing Officer agreed with the parents that Kevin's behavior was a manifestation of his disability. Because Kevin has ADHD, he does not have the necessary executive functioning to inhibit impulses or to anticipate consequences; therefore, his problem behaviors are caused by and have a substantial relationship to his disability.

Anna is a 13-year-old student who has a learning disability and is eligible for special education and related services. Anna's parents enrolled her in the Private Academy for fifth grade; her frustration, inappropriate behaviors, and inattention had increased during fourth grade. In its year-end report, the Private Academy described Anna's functioning levels fairly positively, although the school also indicated she had struggled in fifth grade and required extra attention. The Private Academy recommended continuation of the program she had been receiving, and described her as a lethargic learner. The District developed an individualized education program (IEP) for Anna and recommended a classroom for students with learning disabilities in a District elementary school; the parents rejected this program and requested a due process hearing, seeking tuition reimbursement for private school, as well as for a program to remediate her. In this case, Anna's IEP was judged as to its appropriateness at the time that it was written, and not with respect to subsequently obtained information about the student. It is important to note that "an IEP is a snapshot, not a retrospective," and that the IEP must take into account what was objectively reasonable at the time that it was drafted. The Circuit Court ruled that the parents could not force the school district to adopt what they perceived to be an even more effective educational program.