How Does the Endrew Case Affect Music Education? Insights from Dr. Alice Hammel

On March 22, the U.S. Supreme Court ruled an 8-0 decision in the Endrew vs. Douglas County School District case, stating schools may not settle for minimal educational progress by students with disabilities. This case focused on a child with Autism Spectrum Disorder (ASD) and Hyperactivity Disorder (ADHD), who was removed from public school by his parents when they argued his provided Individualized Education Program (IEP) was inadequate, as the student was making minimal progress toward his IEP goals. Further, the parents considered his IEP goals to be less than appropriately ambitious.

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By federal law, the Individuals With Disabilities Education Act (IDEA) requires a “free appropriate public education” for all students with disabilities. However, in multiple cases, lower courts have held the law as “more than de minimis,” or being legally insignificant. After the Supreme Court’s decision, the “de minimis” standard has been rejected, potentially changing the landscape of education for students with disabilities.

So how may this affect the future of music education for students with special needs? We interviewed Dr. Alice Hammel, a music educator who leads in the field of students with special needs, to find out more on how this may impact music education:

How does the Endrew vs. Douglas County School District ruling affect the future of music education for students with special needs?  Will this provide expanded access to a music education for those students?

I do not think the Endrew decision will manifest in any increased or expanded access to music for students with special needs. I believe it will result in increased expectations regarding marked progress toward IEP goals in music settings. Our ability to provide challenging curricula and hold high expectations for all our students will become increasingly important as it will be noted as part of IEP progress.

Do you think the ruling will affect the process of developing Individualized Education Programs (IEPs) and make music even more prevalent in IEPs?

I do not think music will become more prevalent in IEPs as a result of this ruling. Because special educators are charged with demonstrating the progress of each student toward goals that are appropriately challenging for them, they will be looking for the same level of rigor in music settings. Progress toward IEP goals will be monitored with an eye toward ‘appropriately ambitious’ attainment and a renewed idea about what FAPE really means for students who need modifications to methods, materials, and classroom environments.

How will this ruling affect music educators and the practices in which they teach?

It is our responsibility to provide two fundamental realities for our students each time we teach them.

  1. We are to provide support for our students and assist them in any way possible to reach the goals set for them. We will provide all accommodations and modifications needed to create a classroom experience that is safe, fair, and within reach.
  2. The second fundamental reality for our students is that we must challenge every student every day. Each student who exits our classroom should know more than when they entered. Too often, students with differences are not challenged each day. Instead, they are left to experience music or to be within the room while other students learn. The Endrew decision reminds us that every child can learn and should be expected to achieve independently ambitious goals. This is a marked change and one we need address in our lesson planning, instructional delivery, and assessments.

For music educators who have never undertaken the task of teaching students with special needs, what would be the best resource for best practices and strategies to get them started?

A fairly comprehensive resource available through NAfME is the website created by the Special Research Interest Group dedicated to Children with Exceptionalities. The website is: and I refer to it often when looking for resources for my teaching. The lists of adaptive instruments, apps, articles, movies, books, and organizations are a terrific place to begin.

About Dr. Alice Hammel:

Alice Hammel

Alice Hammel is a widely known music educator, author, and clinician whose experience in music is extraordinarily diverse. She teaches for James Madison and Virginia Commonwealth Universities in the areas of music education and music theory respectively, and has many years of experience teaching both instrumental and choral music in public and private schools. She has maintained a large, independent flute studio for over 20 years. Dr. Hammel is the chair of the NAfME Special Task Force on Students with Special Needs.

Dr. Hammel has put these varied experiences to great use while compiling a large body of scholarly work. Dr. Hammel is a co-author for two texts: Teaching Music to Students with Special Needs: A Label-free Approach, and Teaching Music to Students with Autism, available through Oxford University Press. A new resource, Winding It Back: Teaching to Individual Differences in Music Classroom and Ensemble Settings, was released in 2016. Dr. Hammel has contributed chapters to several other Oxford University Press resources including Composing our Future (edited by Kaschub and Smith). Dr. Hammel is a contributing author to a variety of resources available through the National Association for Music Education (NAfME) and has published widely in music, arts, special, and general education journals.

Ronny Lau, Public Policy Advisor, April 21, 2017. © National Association for Music Education (