A Call for Amicus Briefs as a Means to Influence Special Education Policy: Lessons Learned From Endrew F.

Abstract

Given the legal nature of special education, a particularly promising avenue for infusing research into practice is through court cases. Recent work has illuminated the influence of amicus briefs in court decisions. An amicus brief is a nonparty brief submitted by a person, group of people, or organization that provides insight and expertise on issues presented in a case. In this exploratory study, we examined how interest groups, through the amicus brief process, used research in a recent Supreme Court case, Endrew F. v. Douglas County School District. The case focused on a fundamental principle at the heart of the Individuals with Disabilities Education Act, the definition of a free appropriate public education, an issue in which researchers, practitioners, and policymakers alike should be interested. Our findings indicate that researchers and research played a limited role in the briefing process. We conclude with a discussion of potential reasons for the lack of research in the briefing process, as well as a call for the field to use amicus briefs as a means to influence special education policy and practice.

Keywords

law/legal issues policy

As researchers focused on issues and topics pertaining to special education, we hope that our work will improve the educational opportunities and outcomes of students with disabilities. We, as a field, have amassed a strong literature base of research-based interventions, strategies, and practices for students with disabilities (e.g., McLeskey et al., 2017; Swanson, Sachse-Lee, 2000; Wong et al., 2015). For instance, research has identified numerous interventions and practices for improving learning and behavioral outcomes for students identified with autism (see Iovannone, Dunlap, Huber, & Kincaid, 2003; Simpson, 2005; Wong et al., 2015). One way we, as a community of scholars, can promote the use of our research is through a multifaceted understanding of how it can be used to inform policy and practice. Specifically, it is important for us to take an active role in the infusion of research into the policy arena during key moments of decision making. Given the legal nature of special education, a particularly promising avenue for influencing policy and practice is through court cases. Courts are responsible for interpreting and providing clarification on pressing educational issues that implicate state law or federal law, including the implementation of federal special education policy, known as the Individuals with Disabilities Education Act (IDEA; 2004).

Over the years, the Supreme Court has decided a number of significant cases that have directly impacted education research, policy, and practice. Within the special education context, in particular, the Supreme Court has issued important decisions regarding a range of issues, including related services, a free appropriate public education (FAPE), attorneys fees, and student discipline. During 2016–2017 term, the Supreme Court decided a highly publicized case, Endrew F. v. Douglas County School District (hereinafter referred to as Endrew F.), which involved a student with autism whose parents were dissatisfied with his progress over the years. The case focused on a fundamental principle at the heart of IDEA, the definition of FAPE, an issue in which researchers, practitioners, and policymakers alike should be interested.

Amicus, or “friend of the court,” briefs are one way in which research can potentially influence court cases. An amicus brief is a nonparty brief submitted by a person, group of people, or organization that provides insight and expertise on issues presented in a case. Recent work has illuminated how amicus briefs have been used in Supreme Court cases (e.g., Horn, Marin, Garces, Miksch, & Yun, 2018; Superfine & Thompson, 2016). Drawing from this body of work, our overarching research question was as follows: How do interest groups, through the amicus brief process, use research to influence special education policy? The following subquestions guided our data collection and analysis: (a) How, if at all, did researchers directly aim to influence special education policy as signatories to amicus briefs in Endrew F.? and (b) How, if at all, did other interest groups seek to indirectly use research to support arguments presented in the amicus briefs in Endrew F.?

Bridging the Gap Between Research and Policy

As a research community, we have long discussed the importance of research-informed policy (e.g., Weiss, 1977). Efforts to bridge the gap between research and policy must consider not only the production side of research but also the consumption side. Publications in academic journals are often prepared for academic audiences, most times with access restricted behind paywalls. As producers of research, we as scholars, stress the importance of public engagement (e.g., Dumas & Anderson, 2014). In an effort to inform policy discussions, we may use several different means to disseminate our findings, including writing policy briefs, presenting at conferences, participating in public hearings, and writing blog posts or op-ed pieces.

On the consumer side, calls for the study of research use have been around for quite some time (e.g., Weiss, 1979). Despite this long history, we still have a great deal to learn about research utilization. Tseng (2012) encourages researchers to consider who might consume research and how they might define, access, interpret, and use research. As consumers, organizations or policymakers may use research for a variety of reasons (Lubienksi, Scott, & DeBray, 2014), including to support ideological perspectives. Furthermore, intermediary organizations (e.g., Council for Exceptional Children) serve a prominent role in the production, consumption, and translation of research in education policy (Jabbar, La Londe, Debray, Scott, & Lubienski, 2014).

The use of research in education law, in particular, is not new (Morgan & Pullin, 2010). In fact, in Brown v. Board of Education (1954), psychologists Dr. Kenneth Clark and Dr. Mamie Clark presented testimony that the Court ultimately considered in reaching its conclusion that the segregation of Black children “from others of similar age and qualifications solely because of their race generates a feeling of inferiority as to their status in the community that may affect their hearts and minds in a way unlikely ever to be undone” (p. 494). According to Welner (2012), there are a number of ways that social science can influence the outcome of a case. Indirectly, researchers can use their research to shape public opinion which can impact elections as well as the opinions and experiences of elected officials such as judges. More directly, researchers can serve as expert witnesses or submit amicus briefs.

A growing body of work has identified amicus briefs as an avenue to use research to influence education policy (e.g., Horn et al., 2018; Superfine & Thompson, 2016). Although there is some debate as to their influence (e.g., Ryan, 2003), amicus briefs present an important opportunity for interested groups to provide context to help judges better understand the nuances of issues beyond their content expertise. The literature has examined the role of research in cases related to race-conscious admissions in higher education (e.g., Horn et al., 2018), diversity in K–12 schools (e.g., Frankenberg & Garces, 2007), and teachers unions (Superfine & Thompson, 2016). Building upon this work, in this investigation, we sought to expand the field’s understanding of the relationship between research and policy through an examination of special education case law.

Research Use in Endrew F.

While the Supreme Court delivered two special education decisions during the 2016–2017 term, here we focus on Endrew F. The other case, Fry v. Napoleon Community Schools (2017), involved a student whose Individualized Education Program (IEP) denied her the opportunity to bring her service dog to school. The legal question before the Court primarily related to considerations that impact the steps a plaintiff must take to initiate legal action that implicates both the IDEA and the Americans with Disabilities Act. Given the specific and procedural nature of the issue before the Court in Fry, we would not expect to see a strong emphasis on research.

Endrew F., on the other hand, is an ideal case to examine because it centered on topics that have been empirically examined or researched. Endrew F. touched on issues regarding the role of IEPs in special education (e.g., Yell & Stecker, 2003) and whether educational and behavioral interventions and strategies can improve outcomes for students with disabilities (e.g., Bellini, Peters, Benner, & Hopf, 2007; Iovannone et al., 2003). Endrew F. specifically examined whether or not IEPs must outline special education supports and services that result in students with disabilities having more than de minimis, or minimal, educational benefit (see Yell & Bateman, 2017). Given that there is an empirical research base that could be used in the arguments of this case (e.g., the effectiveness of academic and behavioral interventions on improving outcomes for students with autism), we were interested in examining how research was both directly (i.e., researchers as signatories) and indirectly (i.e., citations to research) used in the amicus brief process.

Drawing from the work of Marin, Horn, Miksch, Garces, and Yun (2018) to guide our study, we conducted a document analysis of the 16 amicus briefs submitted to the U.S. Supreme Court in Endrew F. We began our analysis by reviewing all of the amicus briefs and creating memos on patterns in and across the briefs. To examine the direct use of research, we identified broad categories of the types of interest groups that submitted briefs (e.g., professional/educational association, government, etc.). To do this, we first created a document with all of the briefs submitted. We then independently coded each of the interest groups into a broad category (e.g., government, professional/educational associations, etc.). Next, we shared our codes. If there was disagreement in how we coded an interest group, we discussed and further analyzed it until we reached a consensus.

Using a similar coding process to the one previously described, we then explored the indirect use of research by identifying the broad types of sources that the interest groups cited in their briefs (e.g., published research articles, reports, etc.). We first created a document that listed each interest group that submitted a brief with the sources they cited. We then independently coded all of the cited sources that were considered “research.” Given that there is much debate on what constitutes research and how it should be defined (see Tseng, 2012), we employed a broad and inclusive notion of the term. We included any sources that involved systematic and objective procedures to obtain reliable and valid knowledge (including both published peer-reviewed journal articles and publicly available research reports). Examples of sources that we did not consider research include citations to dictionaries, general websites, and media (e.g., newspaper articles and blogs). We then coded the sources that we identified as research into broad categories (e.g., nongovernmental reports, education journals, etc.). When deciding how to code these broad categories, we went to the source to determine how they identified themselves. For example, to distinguish between education journals and disability journals, we reviewed a journal’s aims and scope. We later met to discuss and further analyze disagreements in our coding. Afterward, we created tables to visualize our coding and to note patterns across the briefs.

As shown in Table 1, we found that advocacy organizations and nonprofits submitted the largest number of the amicus briefs followed by the government, and professional and educational associations. Notably, there were no briefs submitted by researchers or coalitions/groups of researchers.

Table 1.

Interest Groups.

Category	Interest group
Government (5)	• 118 members of Congress • Former Officials of the U.S. Department of Education • Delaware et al. • Colorado State Board of Education, Colorado Department of Education • United States
Professional/educational association (4)	• National Association of State Directors of Special Education • National Education Association • AASA, the Superintendents Association, et al. • National School Boards Association et al.
Advocacy organizations/nonprofit (7)	• Advocates for Children of New York et al. • National Disability Rights Network et al. • Disability Rights Organizations et al. • Council of Parent Attorneys and Advocates et al. • Coalition of Texans With Disabilities et al. • National Center for Special Education Charter Schools et al. • Council of Great City Schools

In Table 2, we present the frequency and type of research citations used in each brief. The average number of research citations was 8.75, and the range was 0 to 42. Two briefs did not include citations to research of any type (i.e., 118 Members of Congress and Advocates for Children of New York). One brief included 42 research citations (i.e., Disability Rights Organizations). Four out of 16 briefs included research published in educational research journals, with a total of only seven educational research articles cited in all briefs submitted to the Court. Similarly, four out of 16 briefs cited disability-focused publication venues. However, the majority of the 17 disability articles were cited in the Disability Rights Organizations’ brief (11/17). Six out of 16 briefs cited law review articles. Six out of 16 briefs did not cite any published research. Most commonly, briefs cited government reports (12/16, 37 total) and nongovernment reports (10/16 briefs, 38 total).

Table 2.

Social Science Research Cited.

	Published research articles							Unpublished	Reports		Book/chapter	Data table
Interest group	Education	Psychology	Law	Medicine	Disability	Multi	Other	Unpublished	Government	Nongovernment	Book/chapter	Data table
Government
118 members of Congress (0)	0	0	0	0	0	0	0	0	0	0	0	0
Former Officials of the U.S. Department of Education (16)	1	0	0	0	4	1	0	0	2	7	1	0
Delaware et al. (7)	0	0	2	0	1	0	0	0	3	1	0	0
Colorado State Board of Education, Colorado Department of Education (9)	0	0	5	0	0	0	0	0	3	0	1	0
United States (1)	0	0	0	0	0	0	0	0	1	0	0	0
Professional/educational association
National Association of State Directors of Special Education (8)	0	0	4	0	0	0	0	0	2	1	0	1
National Education Association (6)	1	0	0	0	0	1	0	0	0	4	0	0
AASA Superintendents Association et al. (8)	0	0	2	0	0	0	0	0	2	4	0	0
National School Boards Association et al. (9)	0	0	0	0	0	0	0	0	4	3	2	0
Advocacy/nonprofit organizations
Advocates for Children of New York et al. (0)	0	0	0	0	0	0	0	0	0	0	0	0
National Disability Rights Network et al. (3)	0	0	0	0	0	0	0	0	2	0	1	0
Disability Rights Organizations et al. (42)	4	2	0	4	11	1	0	0	11	6	3	0
Council of Parent Attorneys and Advocates et al. (5)	1	0	0	0	1	0	0	1	2	0	0	0
Coalition of Texans With Disabilities et al. (9)	0	0	2	0	0	0	1	0	3	2	1	0
National Center for Special Education Charter Schools et al. (11)	0	0	0	0	0	0	0	0	0	7	4	0
Council of Great City Schools (6)	0	0	1	0	0	0	0	0	2	3	0	0
Total	7	2	16	4	17	3	1	1	37	38	13	1

Discussion

Our analysis documents the limited role of research as interest groups set out to craft legal arguments and influence the Court’s ruling in Endrew F. First, in terms of the direct role, we as scholars in special education did not submit a separate brief to present research germane to the issue before the Court. In contrast, educational researchers have submitted briefs in other recent education cases at the Supreme Court level. For example, in 2012, as the Supreme Court was set to rule on a significant case addressing race-conscious admissions policies in higher education, 444 social science researchers signed a brief highlighting the importance of diversity in higher education (Brief of American Social Science Researchers, 2013). According to the brief,

Amici curiae have an interest in presenting to the Court research findings relevant to the educational judgments of The University of Texas at Austin (“the University”), and to the possible implications of the Court’s decision for other institutions and programs. The brief draws from the amici’s original research and their review of the literature . . . We believe it is vital that the Court have the newest and most rigorous peer-reviewed research and statistical analyses when considering an issue that is so critical for all of the nation’s selective colleges and universities. (pp. 1–2)

The American Educational Research Association (AERA) also submitted a brief in this case (Brief of the American Educational Research Association et al., 2013). Similarly, in Parents Involved v. Seattle School District No.1 (2007), social science researchers submitted a brief to alert the Court about the value of diversity in K–12 schools and the negative implications of racial isolation. Educational scholars also participated in multiple briefs submitted to the Supreme Court in a 2016 case, which asked the Supreme Court whether school districts are required to provide access to bathrooms consistent with students’ gender identities (e.g., Brief of Scholars Who Study the Transgender Population, 2017). Most recently, at the district court level, a group of 531 scholars signed on to a brief in support of Harvard’s admissions policy, which encompasses a whole-person approach (Brief of 531 Social Scientists and Scholars on College Access, Asian American Studies, 2018). Grounded in research, the brief argues that Harvard’s approach benefits all students, by allowing each perspective student to be assessed based on their individual merits and experiences while prioritizing the multifaceted value of diversity in higher education. These examples illustrate instances wherein educational scholars have come together to shape policy through research. However, the task of accomplishing this collaborative effort should not be oversimplified, particularly in the field of special education.

There are several factors that may influence whether or not various groups submit amicus briefs to the Supreme Court. For example, reaching a consensus on contentious issues such as those before the Court may present some challenges. Similarly, depending on the topic of a particular case, disciplinary silos may prevent researchers from coming together as a community. Researchers may also not be aware of the status of cases that are making their way through the courts. Another possibility is that researchers are hesitant to use research to inform policy based on concerns regarding the generalizability of research findings. Nonetheless, it is crucial for us, as researchers, to play an active, direct role in bridging the gap between research and policy, and case law presents a vital opportunity to engage with policy. Even where the direct influence on a case is not evident, research stresses the important and nuanced role that amicus briefs can have in shaping public opinion and discourse (e.g., Horn et al., 2018; Welner, 2012).

Published research played a limited indirect role as well. Comparatively, government and nongovernment reports were referenced in most briefs and with higher frequency. We acknowledge that university-affiliated researchers may author or contribute to government and nongovernment reports, either as consultants or affiliates of research centers. Even so, the difference between published journal articles and publicly accessible research reports is worthy of attention. Mirroring this study, other researchers have similarly examined how organizations indirectly use research through the amicus brief process (e.g., Garces, 2013a; Marin et al., 2018). However, in other areas of education law, researchers have found stronger connections to social science research than those that we identified in Endrew F. For example, in a study examining the use of social science in a recent Supreme Court case related to the use of race conscious admissions policies in higher education, Marin and colleagues (2018) found that peer-reviewed, social science journal articles comprised the largest proportion of nonlegal sources cited in amicus briefs. Nonetheless, their work acknowledged that producers of social science research may still argue that social science research was underutilized in the amicus brief process. Taken together, prior research and the present findings implicate both accessibility and consumability. Research must be brought to these conversations in “deliberate and thoughtful ways” (Pfleger, Wilson, Welner, & Bibilos, 2018, p. 3). Furthermore, it is critical for the research community to build upon efforts to promote open access journals.

Researchers have conducted significant research related to the issue before the Court in Endrew F. In some instances, the connection is immediately evident. For example, Zirkel (2013) addresses the issue head-on in an article titled “Is It Time for Elevating the Standard for FAPE Under IDEA?” Similarly, in 2012, Etscheidt published an article titled “Complacency With Access and the Aggregate? Affirming an Individual Determination of Educational Benefit Under the Individuals With Disabilities Education Act.” These examples demonstrate that some researchers are making explicit connections to issues before the Court. However, beyond these explicit connections to legal terms of art such as educational benefit and FAPE, more broadly, the case is about expectations for students with disabilities. This is an issue that cuts across many active areas of research such as the role of IEPs in the provision of special education supports and services, and the effectiveness of different educational and behavioral interventions for children with autism. With only seven educational research articles cited in all briefs, it is evident that the briefs did not begin to scratch the surface of relevant literature.

Conclusion

Endrew F. addressed a significant issue in special education policy, FAPE. Through this article, we hope to call on the field to think more about the courts as an avenue to influence policy. In order for interested groups to utilize research, we must actively engage with organizations, prioritize open access journals, and disseminate research findings through multiple avenues. Garces (2013b) recommends a number of steps that researchers should take to bridge the gap between research and policy. First researchers must understand the legal standard that the court will apply. A firm grasp on the legal standard will help to identify research studies that may be relevant to the court’s analysis. Garces also stresses the importance of using clear, nontechnical language. Furthermore, “expressly stating how the findings relate to each legal question in the case further helps a legal audience understand how findings bear on the legal determination” (Garces, 2013b, p. 175). Finally, Garces encourages scholars to follow case law in the early stages and build relationships with legal advocates, as this allows for more time to conduct research relevant to the specific issue before the court.

Because special education law is a highly litigious area of education law, it is likely that we will continue to see high profile litigation in this area. In Endrew F., the Court held that a student’s IEP must be “reasonably calculated to enable a child to make progress in light of the child’s circumstances.” According to the Court, a student’s “educational program must be appropriately ambitious in light of his circumstances” and “every child should have the chance to meet challenging objectives” (p. 14). While the Court attempted to clarify the legal standard, some ambiguity remains. Since Endrew F. was decided, a few cases have begun to work their way through the courts. To influence policy, it is critical to be involved in these cases at various stages of litigation, including at the circuit court level, particularly because few cases reach the Supreme Court level. Disseminating existing research, building relationships with organizations and lawyers, and conducting research relevant to specific issues with which the courts are currently grappling will be important to bridging the gap between research and policy in the context of litigation. Moreover, using legal terminology in research will help lawyers and organizations identify relevant research. For direct involvement, researchers will need to work together to clearly synthesize existing research, avoiding overly academic or theoretical language. The content of special education-related amicus briefs would vary, depending on the legal issue raised in the case (e.g., FAPE, student discipline, attorneys fees, etc.). However, similar to other areas of law, each brief would be prepared in collaboration with an attorney of record. The brief would likely include a summary of the legal argument, followed by a more detailed analysis of the argument, broken down by section, with relevant educational research threaded throughout the document. The brief should aim to provide the court with a research-based context for understanding the facts of the case, the legal issue before the court, and the potential implications of a decision in favor of either party. These will be essential steps for future cases addressing a FAPE and other special education issues that are or will be the subject of litigation.

Footnotes

Declaration of Conflicting Interests

The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) received no financial support for the research, authorship, and/or publication of this article.

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