In the 1981 case Board of Education of the Hendrick Hudson Central School District, Westchester County, et al. v. Rowley, by her parents, Rowley et ux., the U.S Supreme Court ruled on a matter concerning special education for children with disabilities under the Individuals with Disabilities Education Act (IDEA). Amy Rowley was a deaf student who excelled academically despite receiving only limited services from her school district in New York State. Her parents sued for more comprehensive assistance including a sign language interpreter in all classes which they believed she was entitled to under IDEA. The court held that while IDEA requires states to provide disabled students with "access" to public education, it does not guarantee any particular level of education once access is provided. Therefore, as long as Amy was able to keep up with her non-disabled peers and advance from grade-to-grade successfully without additional support like an interpreter present at all times during class hours - even if she could have achieved more had such support been given - then there would be no violation of IDEA.

In the dissenting opinion for Board of Education v. Rowley, Justice Blackmun argued that the majority's interpretation of "appropriate" education was too narrow and failed to fully consider Congress' intent in passing the Individuals with Disabilities Education Act (IDEA). He contended that IDEA aimed not just at providing access to public schools but also ensuring a meaningful educational benefit for disabled students. The majority's decision, he believed, undermined this goal by setting a low bar for what constituted an appropriate education - merely more than de minimis progress. Instead, Blackmun suggested that courts should require school districts to provide services sufficient enough to help disabled students make significant academic progress commensurate with their potential. This standard would better reflect Congress' intent and ensure equal educational opportunities for all children regardless of disability status.