Hudson v.

Rowley

Case Brief Regarding Individual with Disabilities Education

Act:

Hendrick Hudson Dist. BD. of ED. v. Rowley 1982

Derek Cobb, Graham Witherspoon, Ryan Kulakowski

April 29, 2020
Dr. Bill Harrison, ELP 518: Law for School Administrators
Hudson v. Rowley

Case Caption

The official case site is Hendrick Hudson Dist. BD. of ED. v.

Rowley 1982, 80-1002. Full case name: Board of Education of
the Hendrick Hudson Central School District, Westchester
County, The Commissioner of Education of the State of New
York, Petitioners v. Amy Rowley, by her parents Clifford and
Nancy Rowley, and Clifford and Nancy Rowley in their own
right., Respondent
Hudson v. Rowley

Nature of the Case

Furnace Woods School refused to provide deaf student

Amy Rowley with a sign language interpreter. Amy was an
excellent lip reading and had minimal residual hearing.
School administrators, along with a sign language expert,
determined Amy was able to succeed in school without an
interpreter.
Hudson v. Rowley
Facts

Furnace Woods School refused to provide deaf student Amy Rowley

with a sign language interpreter. Amy was an excellent lip reading
and had minimal residual hearing. School administrators, along with
a sign language expert, determined Amy was able to succeed in
school without an interpreter. Amy’s parents sued the school on her
behalf for violation of the Education of All Handicapped Children Act
of 1975. The Act requires all schools that accept federal funds to
provide a “free appropriate public education” to all handicapped
students. The Act also allows schools discretion in deciding what
steps to take to accommodate handicapped students.
Hudson v. Rowley

Procedural Summary
Plaintiff = Amy Rowley, by her parents Clifford and Nancy Rowley, and Clifford and
Nancy Rowley in their own right.

Defendants = Board of Education of the Hendrick Hudson Central School District,

Westchester County, The Commissioner of Education of the State of New York

The district court ruled in the Rowleys' favor, holding that while Amy was doing better
in school than the average hearing student, she was not achieving to her full potential
because she was unable to understand as much as she would with a sign language
interpreter. The U.S. Court of Appeals for the Second Circuit affirmed.
Hudson v. Rowley

Issue
What does “free and appropriate public
education” require in the context of the
Education of All Handicapped Children Act
of 1975?
Hudson v. Rowley
Holding and Decision

● The District Court ruled in favor of the Rowley’s. They claimed that
even though Amy was doing better than average hearing students,
she was still not meeting her full potential because she could not
understand as much of the classes as hearing students.

● The US Court of Appeals Second Circuit affirmed the decision

● The Supreme Court ruled 6 to 3 to overturn the Second Circuit. They

held that a school does not have to provide an interpreter because
she was receiving a substantially equal education to the hearing
students.
Hudson v. Rowley
Comment - Case analysis
• The court ruled 6-3 that “the Act does not require a school
to provide a sign language interpreter to a deaf student
when she is otherwise receiving personalized instruction
and an adequate education.”
• “School administrations are allowed to determine what is
required to meet a handicapped students’ individual
needs.”
• Justice Blackmun wrote “no interpreter was required
because Amy was given the opportunity to learn and
participate in the classroom in a way that was substantially
equal to her non handicapped classmates. “
Hudson v. Rowley
Comment - Case analysis
• Justice White wrote a dissent stating “that the act requires
a school to provide a handicapped student with an
education equal to non-handicapped children.”
Hudson v. Rowley

Comment - Implications for applicability

● Does access to a free appropriate education allow

handicapped children to reach their full potential?

● Who has the right to determine what is appropriate?

● What does making sure scholars reach their full potential

mean?
Hudson v. Rowley
Questions to Consider
1. How will you determine what are appropriate accommodations or modifications
for students with disabilities? Who will be involved in the decision?

2. How will you know if your school is doing enough for each student with a
disability?

3. What will you do when a parent challenges the accommodations you provide?
Especially if you think it’s enough?

4. What will you do if you do not have the funding or staff to accomodate a
student with a disability?