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Background: Spinal muscle atrophy (SMA) is a genetic disorder of the motor neurons resulting in muscle atrophy and weakness of varying degrees based on severity and type. Although there is current research regarding forms of gene therapy and medications to treat this disease, there is limited research on the most effective physical therapy interventions, especially for more severe types. Purpose: The purpose of this case study is to discuss the therapeutic benefits of aquatic physical therapy in an individual with compromised neuromuscular control, even when gross motor outcome measures did not reflect measureable change. Case Description: The patient was a 17 year old male diagnosed with severe type II spinal muscle atrophy. His primary goals for therapy were to address back, wrist and neck pain. As a child, he never reached any gross motor developmental milestones. He utilized a power-wheelchair for mobility and required maximal assistance for all transfers. Intervention: The patient was seen for one land-based session and one aquatic-based session each week over the course of two years. Outcome Measures: Manual muscle testing and a SMA specific outcomes assessment did not indicate any measurable change in function. However, the PedsQL may be indicated to demonstrate improved quality of life. Discussion: The use of aquatic physical therapy for individuals with degenerative neuromuscular disorders can provide an environment of safety that optimizes their ability to utilize volitional muscular control even in the absence of measureable gross motor gains. Therapeutic benefits of aquatic physical therapy interventions in cases like this may be measured best by use of quality of life measures, such as the PedsQL.