Access to public education through IDEA was affirmed in 1982 in "Board of Education v. Rowley", but the quality of guaranteed education for students with disabilities under IDEA had not been addressed. This Supreme Court case has the potential to "affect the education of 6.7 million children with disabilities" as the Court "struggles "to decide whether it should require public schools to do more under a federal law that calls for them to provide a free education that addresses the children's needs." In the Solicitor General's Amicus brief, the Supreme Court was advised that "Resolving the conflict among the circuits will ensure that millions of children with disabilities receive a consistent level of education, while providing parents and educators much-needed guidance regarding their rights and obligations." On November 21, 2016, 118 lawmakers filed a bicameral amicus brief supporting the rights of students with disabilities to receive a "meaningful" public education. Since August 2016, National Education Association (NEA), the United States' largest trade union, former officials of the U.S. Department of Education, the National Disability Rights Network, the National Education Association, the Council of Parent Attorneys and Advocates, the National Center for Special Education in Charter Schools, and others have "submitted amicus briefs in support of the child." Supreme Court Justices Stephen G. Breyer, Samuel A. Alito Jr., and Anthony M. Kennedy expressed concerns about the implications of implementing IDEA with changes in quality of education standards. Breyer cautioned about potential rising costs of litigation, for example, extraneous lawsuits. Kennedy questioned the financial cost to districts with severely disabled students; Alito considered the burden on poorer school districts. Not all of the eleven circuit courts have considered the issue of standards and in those that have, only two set "meaningful educational benefit" standard. The Supreme Court will decide whether a uniform standard should apply nationally. Alito expressed frustration with the "blizzard of words" produced in the last thirty years of appeals courts hearings which offered different views on standards. Justice Ruth Bader Ginsburg cited the "Board of Education v. Rowley (1982)" in which the Court held that public schools were "not required by law to provide sign language interpreters to deaf students who are otherwise receiving an equal and adequate education." The lawyer for the parents, Jeffrey L. Fisher, claimed that schools should provide "substantially equal educational opportunities" and in most cases, the costs involve "things like providing Braille textbooks, providing an iPad, providing some specialized instruction by a staff member who's already on staff...[T]here are going to be some extreme cases...[IDEA] does not permit cost to trump what the act otherwise requires.