Legal standards for an appropriate education in the post-Rowley era.

In 1982 the U.S. Supreme Court held than an appropriate education under the Individuals with Disabilities Education Act was one that was formulated in accordance with the Act's procedures and that conferred some educational benefit on students with disabilities. Initially, the lower court applied this terminology strictly and approved any proposed individualized education program that conferred even minimal educational benefit. However, later courts began to take a more liberal approach and held that the educational program must confer some meaningful benefit. A careful reading of the Supreme Court's 1982 decision indicates that this recent approach is consistent with Congress's and the Court's intent. The Court never intended to establish one test of appropriateness since it recognized that some flexibility was needed to determine what would be appropriate for a diverse population of students with disabilities.