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The primary message of the Supreme Court's ruling in "Endrew F. v. Douglas County School District" (hereinafter "Endrew F.," 2017) was that school districts are obligated to "offer an IEP [individualized education program] that is reasonably calculated to enable the child to make progress appropriate in light of the child's circumstances" ("Endrew F.," 2017, p. 1001). It is through the present levels of academic achievement and functional performance (PLAAFP), annual goals, services, and methods to monitor student progress that special educators can ensure that their students' IEPs are designed to enable them to make academic and functional progress. The purpose of this article is to assist IEP teams to (a) connect students' areas of need as defined in the PLAAFP statements to the rest of the IEP, (b) write legally defensible IEP goals that are ambitious and meaningful, (c) develop special education and related services based on peer-reviewed research (PRR), and (d) monitor a student's progress toward their goals. Each of these components working together is essential to developing IEPs that enable a student to make progress appropriate in light of their circumstances.

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.

One of the most important elements of an individualized education program (IEP) is the section on present levels of academic achievement and functional performance (PLAAFP). A well-crafted PLAAFP statement should summarize all aspects of a student's present levels of performance in order to identify the strengths and needs of the student as well as the student's baseline level of functioning or progress. To help guide IEP teams in developing a comprehensive PLAAFP statement that summarizes the student's current levels of performance and provides information about how the student's needs or disability impacts educational performance, the present authors have developed a PLAAFP Worksheet. Potential areas of impact are represented on the worksheet, with suggested data sources to be considered when drafting the PLAAFP statement.

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.

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.

A critical requirement of the Individuals with Disabilities Education is that school personnel and parents collaborate in the development and implementation of students’ special education programs. Collaboration has been a crucial requirement of the IDEA since 1975. Collaboration is necessary in formulating student’s special education services and implementing programs that meet students’ needs. In this article, we examine the critical importance collaboration plays in special education law. To do so we examine (a) the history, evolution, and language of the IDEA; (b) rulings of the U.S. Supreme Court and other courts addressing issues in collaboration; and (c) regulations and policies from the U.S. Department of Education. To meet the mandates of the IDEA, school districts need to employ general education teachers, special education teachers, and building-level and district-level administrators with skills in collaborating to support the education of all students and to meet the requirements of the IDEA. [ABSTRACT FROM AUTHOR]

In this chapter, we focus on specially designed instruction (SDI) as a core value for the field of specific learning disabilities (SLD). SDI is at the heart of special education, and the field of LD has been built on the core value that effective instruction improves student outcomes. We describe a two-step test and an extended example of what is and is not SDI for Matt, a student with an SLD. Finally, we discuss some of the confusion surrounding SDI and the need for the field to return to its core value of individualized, intentional, targeted, evidence- or high leverage practice--based, and systematic instruction for students with SLD. [ABSTRACT FROM AUTHOR]

The Supreme Court decision in Endrew F. v. Douglas County School District (2017) established a higher standard of what constitutes an appropriate education for students receiving special education. In contrast to the previous standard provided in the Board of Education v. Rowley (1982) decision, which established that some benefit (even minimal or trivial benefit) was acceptable, the Endrew F. decision reflected a higher standard for the delivery of special education. Specifically, special education should result in measurable progress toward individualized education program goals. This article explores what it means for special education teacher educators to prepare teacher candidates to meet this higher standard. In particular, how a focus on instruction (i.e., the delivery of specially designed instruction) rather than a focus on access to the general curriculum is necessary in order for meaningful, measurable change to occur in the outcomes of students with high-incidence disabilities will be explored. [ABSTRACT FROM AUTHOR]

The article presents a case study of a student who received supplementary services through an individual education program (IEP) for giftedness in two different school districts in elementary school and later was found eligible as a student with a learning disability due to difficulty with mathematical calculations and anxiety around school performance. Beginning in ninth grade he received no special provisions. His academic decline, the family's request for assistance, the development of an IEP for the student, and the attempts by the parents' to obtain for him a "free appropriate public education" (FAPE) as mandated by U.S. law are described, as are the District's obligatory accommodations to compensate for the student's prior denial of his rights to the special education program.

An introduction is presented in which the editor discusses various reports within the issue including the experiences of special education teachers in their school sites, the impact of varied special education skills to school leadership and the essential leadership skills in special education.