Page 12 - Special Education One Sheets

Case Examples

> Repeating goals year after year may indicate a student is not receiving a FAPE. Where goals are
inappropriate in light of the student’s abilities or are identical to goals from prior IEPs, a court may
find that they are an indication that the student has not been offered FAPE or is not making progress.
(Endrew F. v. Douglas County Sch. Dist. RE-1, 69 IDELR 174 (U.S. 2017).)

> Avoid vague and immeasurable goals. Because the goals in the child’s IEP were expressed in subjective
and inexact terms such as “to increase participation,” and “to increase compliance,” the team could not
make an objective analysis of whether the child was making progress toward his goals and objectives.
(Anchorage Sch. Dist., 51 IDELR 230 (SEA AK 2008).)

> Each IEP goal should have corresponding items of instruction or services. Having goals without related
programming indicates that the district is not providing FAPE. (Burlington Sch. Dist., 20 IDELR 1303 (SEA
VT 1994).)

> An IEP should pass the “stranger” test. Under this test, an IEP goal is appropriate if a person unfamiliar
with the IEP would be able to implement the goal, implement the assessment of the student’s progress on
the goal, and determine whether the student’s progress was satisfactory. (Mason City Cmty. Sch. Dist., 46
IDELR 148 (SEA IA 2006).)

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