Orton-Gillingham and the IDEA: analysis of the frequency and outcomes of case law

The Individuals with Disabilities Education Act grants dissatisfied parents of students with disabilities the right to pursue legal remedies. In 2007, Rose and Zirkel found that parents of students with reading disabilities seeking Orton-Gillingham (OG) instruction under the IDEA's central obligation for a free appropriate public education (FAPE) were largely unsuccessful in their complaints. Since that review, various factors had the potential to influence the frequency and outcomes of OG-related case law-namely, the peer-reviewed research requirement of the IDEA and growing awareness of the need for specialized reading instruction. Our updated analysis of OG-related case law revealed an increase in the number of cases but similar district-favored outcomes identified by Rose and Zirkel. In particular, the relaxed substantive FAPE standard and deference to local and state authorities diminished the likelihood of parents prevailing in their requests. Implications for parents, school district personnel, special education professionals, and education researchers are presented.