Abstract
Although most special education experts anxiously awaited the Supreme Court's decision during the 2016-2017 term in Endrew F. v. Douglas County School District RE-1 as an opportunity to overturn the Supreme Court's decision in Board of Education v. Rowley, the most important case of the term was actually Fry v. Napoleon Community Schools. The Fry decision seemingly broadened the situations in which parents of children in special education can pursue remedies on behalf of their children under the Americans with Disabilities Act or Section 504 without exhausting their IDEA remedies. Specifically, a child like Amy Rowley, who is deaf can now attain success under Section 504 or the ADA even though she failed to attain relief under the IDEA. The Fry decision has dramatic consequences for special education students who are seeking effective communication in the classroom.
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