ABSTRACT
In the decades following the passage of the EAHCA, the question of what exactly constituted a free and appropriate public education has generated much
discussion, controversy, and litigation. Our purpose is to review the FAPE requirement of the IDEA. First, we examine the defi nition of a FAPE in the IDEA and show how the meaning of FAPE has evolved. Second, we review cases that have examined the FAPE principle, including the fi rst special education case heard by the U.S. Supreme Court, Board of Education of the Hendrick Hudson School District v. Rowley (1982). Third, we offer guidance to school districts to meet this most important principle of the IDEA.
