Many schools and districts transitioned to remote teaching and learning environments in lieu of face-to-face instruction in 2020 as a response to the COVID-19 global pandemic. This new service delivery model proved to be challenging for teachers and service providers who were offering specialized instruction and related services to students with disabilities. Parents and advocates soon became concerned about the extent to which FAPE was provided these students. Although schools closed in the spring of 2020, legal challenges to the provision of FAPE have only recently appeared on court dockets. The purpose of this paper is to present the authors’ analysis of recent case law that focuses on the provision of FAPE during the pandemic for children with disabilities generally and for children with intellectual disabilities specifically. They are interested in learning how the courts are weighing the unique circumstances that replaced traditional schooling for these students in light of the requirement to provide FAPE as it is defined in statutory and case law. The authors will contextualize the instructional program and related services provided during the school shut-down and explore how courts are determining whether school districts were adhering to IDEA during this time.