Equal Educational Opportunities Act of 1974
Congress passed the EEOA as a house bill amending the Elementary and Secondary Education Act of 1965. The only legislative history available for reference is from a similar bill passed in 1972. The House Committee on Education and Labor noted that the bill was significant in that it contained the first "illustrative definition of a denial of equal educational opportunity", and that this lent clarity to schools, governmental authorities, and students as to what, precisely, their rights were.
Board of Education of the Hendrick Hudson Central School District v. Rowley
In the early 1970s, a series of Federal District Court cases – namely "Pennsylvania Association for Retarded Children (PARC) v. Commonwealth of Pennsylvania" (1971) and "Mills v. Board of Education of District of Columbia" (1972) – found a right to education for children with disabilities on the basis of due process and equal protection. A 1974 investigation by Congress found that more than 1.75 million children with disabilities received no public education and that another 3 million who did attend school did not receive education services appropriate to their needs. In 1975 Congress passed and President Ford signed into law the Education for All Handicapped Children Act (EAHCA). The Act mandated that all children with disabilities receive a "free appropriate public education." To achieve this goal, the act required the student, parents and teachers together devise an Individualized Education Program (IEP), however the Act did not specify that those IEPs include any particular services, standards or outcomes. 
In 1976, respondents Clifford and Nancy Rowley met with the principal of Furnace Woods Elementary School in the Hendrick Hudson Central School District of Montrose, New York to discuss accommodations for their hearing-impaired daughter, Amy Rowley, who would be starting kindergarten there the following year. After having placed her in a regular kindergarten class on a trial basis, Amy was provided with an FM hearing aid and completed her kindergarten year, advancing on to first grade. In accordance with the Education for All Handicapped Children Act, an IEP was created for Amy which included the continued use of her FM hearing aid, but did not include a sign language interpreter. The school, in consultation with the school district's Committee on the Handicapped, contended that Amy did not need an interpreter. Her parents disagreed with that finding and received a hearing with an independent examiner. The examiner concluded that "Amy was achieving educationally, academically, and socially without such assistance." After losing their appeal to the New York Commissioner of Education, the Rowleys brought suit in the United States District Court for the Southern District of New York contending that denial of a sign language interpreter violated the EAHCA's guarantee of a free appropriate public education.