In a 6–3 decision authored by Justice Rehnquist, the Court held that public schools are not required by law to provide sign language interpreters to deaf students who are otherwise receiving an equal and adequate education.
In the early 1970s, a series of Federal District Court cases – namely Pennsylvania Association for Retarded Children (PARC) v. Commonwealth of Pennsylvania (1971) and Mills v. Board of Education of District of Columbia (1972) – found a right to education for children with disabilities on the basis of due process and equal protection.
In 1975 Congress passed and President Ford signed into law the Education for All Handicapped Children Act (EAHCA).
"[3] After losing their appeal to the New York Commissioner of Education, the Rowleys brought suit in the United States District Court for the Southern District of New York contending that denial of a sign language interpreter violated the EAHCA's guarantee of a free appropriate public education.
At the evidentiary hearing, the Rowleys presented evidence that showed Amy, despite her academic success so far, was not able to fully achieve in the classroom with the resources available.
[4] They provided test results showing that Amy understood only about 60 percent of discussion in the classroom, while an interpreter would put her closer to 100%.
They further provided results from two academic achievement tests Amy took in first grade, one administered in English and the other in American Sign Language.
Because of his determination that Amy would be more successful with an interpreter, Judge Broderick ruled that failure to provide her with one violated the Education for All Handicapped Children Act.
[6] The requirements of the act, Judge Broderick argued, fell somewhere between a simply "adequate" education and one that allows the student to achieve their full potential, neither extreme being possible.
[10] Kuntz also raised the argument that determinations of educational services and content were, constitutionally, matters delegated to the states.
"[16] Arguing on behalf of the United States in support of the respondents, Elliot Schulder focused largely on matters of statutory interpretation rather than specific outcomes for Amy.
When pressed by the justices regarding the educational standards required, he contended that the district court opinion went too far: "the emphasis is not on potential or shortfall from potential, but on the making available to handicapped children the same opportunities that are available to non-handicapped children to benefit from the regular educational program that the state or local school authorities provide.
"[24] In his concurrence, Justice Blackmun disagreed with the majority's finding of legislative intent, quoting his previous concurrence in Pennhurst State School v. Halderman: "it seems plain to me that Congress, in enacting this statute, intended to do more than merely set out politically self-serving but essentially meaningless language about what the handicapped deserve at the hands of state authorities.
"[28] Quoting San Antonio Independent School District v. Rodriguez, the Court reiterated that the judicial branch lacks the expertise "to resolve persistent and difficult questions of educational policy.
"[29] Since the Supreme Court made its ruling on the basis of a statute (the EAHCA), not the Constitution, the precedent is only controlling so long as the relevant language of the law remains in effect.
v. Mercer Island School District (2006), U.S. District Court Judge Marsha J. Pechman wrote that the IDEA reauthorization of 1997 represents "such a significant departure from the previous legislative scheme that any citation to pre-1997 case law on special education is suspect," though Judge Pechman's decision was overturned by the Ninth Circuit Court of Appeals in 2010.
Rowley stated decades later that when the school district found out they were moving, they put a lien on the house to recover their costs in litigation.
"[35] Likewise, in a 2012 article, Mark C. Weber wrote that Rowley "remains the most important American special education case ever decided.
[37] In a 2005 article published in the Suffolk University Law Review, Lester Aron also noted that circuit courts of appeal have issued conflicted rulings when interpreting Rowley.