Supreme Court Board of Education of the Hendrick Hudson Central School District v. Rowley

michael a. chatoff, deaf lawyer, represented rowleys. though deaf, chatoff able speak , delivered arguments orally in english while able respond justices questions using computer-aided transcription system involving stenographer , computer monitor supplied gallaudet university , translation systems, inc. equipment had specially approved court, , first time court approved use of such electronic equipment , first time deaf person argued before supreme court.

chatoff argued goal of act provide handicapped children equal educational opportunities. asked justify interpretation, chatoff pointed legislative record arguing intent of legislation rather text of statute specifically. justices questioned him implications of upholding such interpretation, interpretation of statute require every school board provide sign language interpreter every deaf child in country? chatoff argued case specific amy , distinguished between amy needed , other students situated may or may not need: deaf community not monolithic entity....not every deaf child can educated in public school....children educated in special schools or in research rooms have no need interpreters. children raised using oral method have no need interpreters. specific instances.

arguing on behalf of united states in support of respondents, elliot schulder focused largely on matters of statutory interpretation rather specific outcomes amy. when pressed justices regarding educational standards required, contended district court opinion went far: emphasis not on potential or shortfall potential, on making available handicapped children same opportunities available non-handicapped children benefit regular educational program state or local school authorities provide. justices brought issue kuntz, petitioner, touched on: s court supposed do? independently make own judgment or ... [say] m allowed decide whether school acted arbitrarily? essentially, should court rule on whether aspects of individual education program allow handicapped child reach full potential or approval of individual education program sufficient satisfy act. schulder argues middle ground: don t think court has measure potential, believe court has make independent determination whether, in particular case, example, plan developed provides child in question access same educational opportunity available non-handicapped children.

on rebuttal, kuntz argued against district court s contention amy understands 59% of occurs in classroom. contended evidence more persuasive show amy understanding without sign language interpreter. district court based finding on word discrimination test conducted outside classroom. experts, observed amy in classroom, had determined amy understands of transpires in classroom.

opinion of court

justice william rehnquist wrote majority.

on june 28, 1982 court handed down 6-3 decision in favor of petitioners. justice william rehnquist wrote majority, justice byron white writing principle dissent joined justices william brennan, jr. , thurgood marshall. court answered 2 questions: meant act s requirement of free appropriate public education ? , role of state , federal courts in exercising review granted 20 u.s.c. § 1415?

the court held both district , appeals courts wrong in contention intent of law provide handicapped children s full potentials rather give them access. overruled district court s finding act not define appropriate education , justice rehnquist quoting text of statute itself: term free appropriate public education means special education , related services followed further definitions of terms. instead, text of legislation , legislative intent show purpose of law not allow each child achieve full potential, provide sufficient resources handicapped children access education. rehnquist pointed text of act creating prioritization of how resources allocated: states receiving money under act must provide education handicapped priority, first handicapped children not receiving education , second handicapped children . . . severe handicaps receiving inadequate education. in concurrence, justice blackmun disagreed majority s finding of legislative intent, quoting previous concurrence in pennhurst state school v. halderman: seems plain me congress, in enacting statute, intended more merely set out politically self-serving meaningless language handicapped deserve @ hands of state authorities. agreed final judgement of court, however, he, majority, believed district court should not have prescribed own remedy should have given greater deference did findings of school district s impartial hearing officer , state s commissioner of education .

they next tackled question of role of courts in judicial review process. under act, parents provided civil cause of action in courts when other administrative appeals exhausted. court rejected petitioners contention right judicial review applied procedural review of administrative appeals , whether decision based on sufficient evidence. likewise stopped short of de novo review rowleys had advocated allow courts prescribe particular educational methods district court had. rather, majority held court must assess 2 question: first, has state complied procedures set forth in act? , second, individualized educational program developed through act s procedures reasonably calculated enable child receive educational benefits? if these requirements met, state has complied obligations imposed congress, , courts can require no more. quoting san antonio independent school district v. rodriguez, court reiterated judicial branch lacks expertise resolve persistent , difficult questions of educational policy.