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Special Education Law Blog

Special Education Law Blog
A fresh look at special education law. Jim Gerl is a frequent speaker on special ed law topics. He has presented at many national and regional conferences, given interviews in various publications and he has consulted with a number of state education
Articles: 1, 2

Articles

Procedural Safeguards - Part I
2008-02-21 21:59:00
We have previously run a series on Dispute Resolution options under IDEA. Dispute resolution is included within the broader topic of Procedural Safeguards under the Act. Today we begin a series in the other IDEA procedural safeguards. Although we won't repeat the items on dispute resolution, we will examine how the IDEA'04 changes and the latest federal regulations impact the other procedural safeguards. We'll hold off on the caselaw until after we take a look at the changes in the law and regs. Today we address the nature of procedural safeguards in general. Procedural safeguards are extremely important under our system of special education. In the seminal United States Supreme Court decision interpreting the predecessor of the Individuals with Disabilities Education Act, 20 U.S.C. Section 1400, et seq, the Court stressed the importance of procedural safeguards in the statutory system adopted by the Congress, noting that the procedural safeguards gave parents a “large me...
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Seventh Circuit: NCLB trumps IDEA
2008-02-15 18:42:00
The United States Court of Appeals for the Seventh Circuit has issued an interesting opinion inBoard of Educ of Ottawa Township High School District 140, et al., v. Margaret Spellings, Secretary of Education, et al., No. 07-2008. The Court affirms the District Court's dismissal of a challenge of NCLB as inconsistent with IDEA but not for lack of standing as the District Court had held. Instead, the Court ruled that NCLB, which was enacted in 2001, must prevail to the extent that there are inconsistencies with IDEA, the portions of which that were at issue were enacted between 1970 and 1990. You can find the decision at http://www.ca7.uscourts.gov/tmp/AU0PHBSR. pdfThe court did allow an interesting loophole. At the end of the opinion the Court noted that the challenge was to the entirety of NCLB, and the Court left open the possibility that portions of the Act, or specific regulations promulgated thereunder might yield. The claim against the entire statute was, however, too weak to a...
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My New Favorite Decision
2008-02-08 21:07:00
Here's a good one. Hearing officers beware.In DB by CB v. Houston Independent School Dist 48 IDELR 246 (D. Texas 9/28/7), the parents argued on appeal that they were deprived of a fair and impartial hearing because the hearing officer slept through the hearing. The District Court rejected the argument, noting that the hearing transcript showed that the HO asked questions of witnesses and resolved evidentiary objections, therefore appearing to be awake. Also the Court noted that the pro se parents had failed to preserve their argument for appeal because they failed to object to the alleged napping on the record during the hearing. Stock up on Mountain Dew or No Dose hearing officers!
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Dispute Resolution Mechanisms - Part VII
2008-02-04 20:40:00
Concluding our discussion of the four dispute resolution options under IDEA, this week we will continue to examine the due process hearing and the major changes in the hearing process under the 2004 reauthorization and the new federal regulations. Last week we examined the changes to the "stay put" provision and procedural violations. This week we will deal with changes concerning NCLB-type issues and miscellaneous hearing issues.NCLB-type IssuesIDEA ’04 imposes new NCLB-type qualifications for special education teachers as well as related services personnel and paraprofessionals. Section 612(a)(14)(B)&(C). However, IDEA also provides that no due process hearing or court action may be filed because of failure to provide highly qualified personnel, although a parent may file a state complaint concerning staff qualifications. Section 612(a)(14)(E). See 34 CFR Section 300.156(e). OSEP clarifies that a parent may not file a due process complaint about a student, or a judicial acti...
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New Feature- Other Education Blogs
2008-01-29 19:47:00
A number of people have asked me recently about other education blogs. I have been hesitant to add a blogroll to this blog because I am still pretty new to the blogosphere. (Eg. Did I use the word "blogosphere" correctly?)(Interestingly, the Blogger spellchecker doesn't like the word!)But there are three education blogs that I read as often as I can. One is the Edjurist Accord which features the work of my friend Justin Bathon. A newer blog that also highlights legal issues I care about is the School Law Blog by Mark Walsh. Finally the Adjunct Law Professor Blog by Mitch Rubinstein often discusses education law developments. I have added links to these three thoughtful and useful blogs on the left hand side of this blog under the title other education blogs. Are there other education or special education or law blogs that you think might be of interest to our readers? If so, please let me know. I will continue to be conservative about recommending blogs until I get the chanc...
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Dispute Resolution Methods- Part VI
2008-01-24 17:06:00
Continuing our discussion of the four dispute resolution mechanisms under IDEA, this week we will continue to examine the due process hearing and the major changes in the hearing process under the 2004 reauthorization and the new federal regulations. Last week we examined the new requirement of hearing notice, including the sufficiency requirement, and amendment of the complaint/notice, changes concerning hearing officer qualifications and the statute of limitations. This week we will deal with changes concerning "stay put," and procedural violations. Stay Put: the child's placement during pendency of due process proceedings OSEP clarified that for purposes of stay put, “placement” is not generally location specific; the then-current placement is the educational program of the last agreed upon IEP which is being implemented. 71 Fed. Register No. 156 at page 46709 (August 14, 2006).Where there is a dispute when the child turns three years old and is transitioning ...
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Why No SpEd Law Classes in Law Schools?
2008-01-18 19:44:00
I have a complaint for the law schools of America. Special Education Law is one of the fastest growing fields of law. Yet very few law schools have courses on Special Education Law. The U. S . Supreme Court has heard argument in four special ed cases in the last few years. Hundreds of judicial and administrative decisions are issued every year. Many law firms have lawyers who specialize in representing school districts or student/parents. Each state has a due process administrative hearing system and a mediation system. Numerous state, regional and national special education law conferences are held every year. No Child Left Behind is a hot button issue in the presidential campaigns. How can our law schools claim that they are training new lawyers who are ready to represent clients well when they don't even offer a course in special education law? I don't get it. I encourage more schools to offer special education law classes. I believe that potential law students may beg...
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Interesting NCLB Decision by the Sixth Circuit: Is Divorce Likely?
2008-01-15 21:06:00
The United states Court of appeals for the Sixth Circuit issued a noteworthy decision last week in Sch Dist of the City of Pontiac v. Spellings. The decision is interesting in that the Court held that the plaintiffs, a number of school districts and a teacher's union, with some of its affiliates, stated a cause of action that the districts are not legally responsible for the costs of implementing No Child Left Behind beyond the funds provided by the federal government for NCLB . The Court relied upon the provision in NCLB prohibiting unfunded mandates.The Court remanded the case to the trial court for resolution on the merits. Accordingly, it has no immediate impact. You can read the slip opinion at http://www.ca6.uscourts.gov/opinions.pdf/ 08a0006p-06.pdfI hear that one in two marriages ends in divorce these days. My question today is - coupled with the current stormy political climate for NCLB, could the marriage of NCLB and IDEA be headed to divorce court?
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Dispute Resolution Methods - Part V
2008-01-11 22:40:00
Continuing our discussion of the four dispute resolution mechanisms under IDEA, this week we will continue to examine the due process hearing and the major changes in the hearing process under the 2004 reauthorization and the new federal regulations. last week we examined changes concerning hearing officer qualifications and the statute of limitations. This week we will deal with the new requirement of hearing notice, including the sufficiency requirement, and amendment of the complaint/notice.3. Hearing NoticeThe changes to the law by IDEA'04 include a new requirement that before a party may have a due process hearing, the party must file a notice to the other party and the SEA including, among other things, a description of the nature of the problem, and a proposed resolution of the problem. Section 615 (b)(7)(B).A party receiving a notice of due process hearing complaint must notify the hearing officer if it believes that the notice is insufficient to meet the statutory requirem...
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Dispute Resolution Methods - Part IV
2008-01-02 21:26:00
Continuing our discussion of the four dispute resolution mechanisms under IDEA, this week we will begin to examine the due process hearing and the major changes in the hearing process under the 2004 reauthorization and the new federal regulations. As many of you know, this is the method where a lot of my work is involved. I am a hearing officer for West Virginia and Utah, and a special hearing officer for Alaska. I work with and train hearing officers from many states, and I consult with states about their due process systems. Many of my comments to the feds when they were contemplating new regs involved the hearing process. Many of the changes in IDEA'04 and the new regs involve the hearing system. I think that Congress and OSEP were expressing at least some dissatisfaction with the hearing system. Special ed law fans should take note!We will begin with the changes in hearing officer qualifications and the statute of limitations.1. Qualifications for Hearing Officer...
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Dispute Resolution Methods - Part III
2007-12-26 20:56:00
Continuing our discussion of the four dispute resolution mechanisms under IDEA, this week we will examine mediation and the major changes in mediation under the 2004 reauthorization and the new federal regulations. As previous posts have noted this is my favorite method. Mediation is the only option which allows repair of the relationship between parents and the school district. A good mediator will work on any relationship issues. Because the ultimate concern is the education of a child, a good on-going relationship is critical.The major change in the mediation section of the law under IDEA’04 is the new requirement that a state must make mediation available to the parties at any time. Section 615(e)(1). The statute previously had only required that mediation be available after a due process hearing had been requested. See 34 CFR Section 300.506(a).OSEP declined the invitation of several commenters to enact a regulation giving due process hearing officers the power to require med...
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Dispute Resolution Methods- Part II
2007-12-19 17:47:00
Last week we described the four dispute resolution mechanisms under IDEA. Beginning this week we will periodically provide posts that describe the major changes in the methods under the 2004 reauthorization and the new federal regulations. Because the resolution session is brand new and because we have discussed it in some detail in previous posts, we will concentrate on the other three dispute resolution methods. This week's post will examine the state complaint procedure. Because this mechanism is not contained in the statute, the discussion will involve the analysis of comments in the federal regulations.State Complaint ProceduresOSEP maintains the state complaint system even though Congress has not specifically provided or addressed a state complaint system in the IDEA. 71 Fed. Register No. 156 at page 46606 (August 14, 2006).The new regulations give SEAs the ability to award compensatory education or reimbursement as part of the corrective action to remedy after a state compla...
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Dispute Resolution: When Parents and School District Disagree
2007-12-13 17:50:00
Some of the work I do in special education law focuses on dispute resolution. Special ed law is new law. Lawyers generally consider anything that came over on the boat from England to be old law; everything else is new. Laws that came into existence in the 1970's are brand new. Lawyers are more comfortable with old law like contracts and property, where there is often a settled "hornbook" answer, and they can advise their clients with relative certainty. So many lawyers are very uncomfortable with special ed issues.To make matters worse, the procedural rules are strange to seasoned attorneys. In most areas of the law, the aggrieved party must pick a forum. In special ed, however, it is possible for an aggrieved party to pursue four different dispute resolution mechanisms- and this is before going to court. Needless to say, this is very frustrating to lawyers who dislike ambiguity. In special ed law, the party who disagrees, usually but not always the parent, has four options ...
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What Should the Supreme Court Decide Next?
2007-12-07 18:00:00
The United States Supreme Court has issued only ten decisions on special education law, including the inconclusive Tom F 4-4 tie. Since the seminal Rowley decision which defined FAPE, and Honig which spelled out stay put and Burlington which established reimbursement for unilateral placements as a remedy for denial of FAPE, some have criticized the Court for tackling tangential issues. Especially lately, the Court has seemed to be nibbling at the edges of the body of special education law. Recent issues have included the burden of persuasion (which only applies in ties); the payment of experts; whether parents without lawyers can represent children with disabilities in federal court; and whether parents of students who never attended public school but who were denied FAPE can seek reimbursement. Moreover, there are two decisions affirming unilateral placements and two decisions interpreting the medical exception to related services.I am aware that the Court is limited to what is...
Misunderstanding Tom F. - Who Pays for Special Ed for Private School Stude
2007-12-02 19:22:00
There seems to be a lot of misunderstanding about the meaning of the recent Tom F. decision by the U.S. Supreme Court. I have talked to a lot of people who feel that the Second Circuit decision, which was affirmed by default, for the Second Circuit only, by the tie vote by the Supremes, requires public school districts to reimburse tuition for many or all private school students. These folks are overlooking one important factor; before tuition may be reimbursed, the parent/student must prove a denial of FAPE. In other words, the school district must either prevent the parents from meaningful participation in the process or else write an IEP that is reasonably calculated to confer no more than trivial educational benefit to the child.Where a child is denied FAPE, the parents must choose between keeping the child in the public school and seeking remedies such as compensatory education and withdrawing the student and placing him in a private school while seeking reimbursement as the pr...
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Special Education Law 101 - Part V Compensatory Education
2007-11-28 04:56:00
As explained in a previous post, I have decided to post a series of Special Ed Law 101 articles to give those outside the SpEd (special education) circle a better chance of understanding what we mean and to get more people hooked on this ever-growing field.Special Ed Law 101- Part III Compensatory Education In addition to reimbursement for unilateral placements, the most common relief awarded to a prevailing parent/student in a special education case. A hearing officer awards compensatory education as a remedy for denial of FAPE to the student. The prerequisite again is a denial of FAPE.The method for determining the appropriate type and amount of compensatory education varies wildly among hearing officers. The most common method has been to determine the period of time equal to the deprivation of FAPE excluding the time reasonably required for the school district to have corrected it. Cumberland Valley Sch. Dist. 106 LRP 20056 (SEA Pa. 2/18/6). See also, Warwick Sch Dist 107...
Beware the New Resolution Session- Part III
2007-11-16 21:16:00
In two previous posts, I described the new requirement of a resolution session where a parent files a due process hearing complaint and some of the anticipated problems with this new requirement. Despite my obvious reservations about the new resolution system, it does seem to be causing more settlements. I am a Cubs fan, I have to be an optimist. Nonetheless the potential for disaster looms. More thoughts in this regard:In response to a commenter who questioned whether a resolution meeting agreement supersedes decisions made by the IEP Team, OSEP stated that nothing in the Act or regulations requires an IEP Team to reconvene following a resolution agreement that includes IEP-related matters. 71 Fed. Register No. 156 at page 46703 (8/14/06).OSEP declined the request of some commenters to require dispute resolution training for parents, although it noted that nothing in the Act prevents a state or local public agency from offering dispute resolution training for parents or from ...
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Special Ed Law 101- Part IV Unilateral Placements
2007-11-09 05:12:00
Special Ed Law 101- Part III Unilateral PlacementsAs we saw in the Tom F. case before the Supreme Court, among the relief that a due process hearing officer may award is reimbursement for a unilateral placement by the parents. In the case of Burlington Sch. Comm. V. Dept. of Educ., et. al. 471 U.S. 359, 105 S.Ct. 1996, 556 IDELR 389 (1985), the Supreme Court was faced with the issue of whether the IDEA permitted courts (and hearing officers) to award reimbursement to parents when the IEP developed by the schools is not appropriate and the parent removes the student from public school and places him in a private school that does provide FAPE. Noting that the statutory provisions of the IDEA confer broad equitable powers upon the courts to fashion an appropriate remedy, and the fact that judicial review of IDEA cases often takes years, the Supreme Court held that the IDEA does empower courts and hearing officers to award such reimbursement. Burlington, supra.In Florence County Sch. Di...
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Hearing Officer Blues: Decisions, Decisions
2007-10-30 18:30:00
I am currently working on two due process hearing decisions. Those of you familiar with special education law understand that I absolutely cannot comment on the facts of the cases.I do want to talk about the process of decision writing, however. This is one of the most important things that I work with hearing officers on while training them. It is a lot more difficult than it looks. There is generally a voluminous record: multi-volume transcripts and a ton of exhibits. From this jungle of paper we must cull findings of fact. Not everything in evidence, just facts of decisional significance. Then we must apply the facts to the law. The law sounds pretty simple, but in fact the IDEA is a huge statute, with amendments that appear to have been cut-and-pasted in almost random fashion, possibly by monkeys. For example, Section 615 is labeled "Procedural Safeguards," yet there are other procedural safeguards set forth in many other places in the Act, and at least a few (e.g., sta...
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Special Education Law 101- Part III
2007-10-22 19:06:00
As explained in a previous post, I have decided to post a series of Special Ed Law 101 articles to give those outside the SpEd (special education) circle a better chance of understanding what we mean and to get more people hooked on this ever-growing field.Special Ed Law 101- Part IIIThe IDEA definition of FAPE, as explained in Part I of this series, includes both special education and related services. This post involves a discussion of issues pertaining to related services.Related ServicesThe IDEA defines related services as follows:(A) IN GENERAL- The term ‘related services’ means transportation, and such developmental, corrective, and other supportive services (including speech-language pathology and audiology services, interpreting services, psychological services, physical and occupational therapy, recreation, including therapeutic recreation, social work services, school nurse services designed to enable a child with a disability to receive a free and appropriate public e...
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Thanks for Your Support-Tenth Place!
2007-10-22 18:54:00
I understand that this blog finished in tenth place for best educational blog and tenth place for best business blog in the Blogger's Choice Awards. In order to vote, people had to first register and then reply to an email, so there was some effort involved. Thank you to all the people who voted for this blog. I really appreciate your support.
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Supreme Court Decides Not to Decide
2007-10-16 19:19:00
Yesterday the U. S. Supreme Court denied certiorari in the case of BD. OF ED., HYDE PARK V. FRANK G., ET UX., Case No. 06-580. Denying cert means that the Court has declined to review the decision of the Circuit Court of Appeals. The Second Circuit decision involved was very similar to the Tom F. case which recently resulted in an anticlimactic 4 to 4 tie. The same issue was presented: whether the parents of a child with a disability who has never received special education from a public school district may receive reimbursement for a unilateral placement of the child in a private school after denial of FAPE by the public school district.Interestingly, Justice Kennedy once again recused himself (ie, he took no part in the decision to deny cert.) I'm wondering whether he had done some legal work for the school districts involved. Maybe he has a grandchild with a disability? If anybody has another theory, please let me know. The mystery of the recusal of the swingman lives...
New Supreme Court Decision
2007-10-11 16:45:00
The U. S. Supreme Court yesterday in Board of Education of the City of New York v. Tom F. affirmed the decision on the Second Circuit Court of Appeals upholding the ruling that a parent of a student with a disability may seek reimbursement for a unilateral placement in a private school even though the student never received special education services from the public schools. The per curiam decision of the court was based upon the Court being equally divided, 4 to 4, with Justice Kennedy having recused himself. A copy of the one page decision may be found at http://www.supremecourtus.gov/opinions/07 pdf/06-637.pdfPer curiam decisions are decisions issued in the name of the Court rather than under the names of specific justices. In the past, per curiams were used for non-controversial and often unanimous matters. They generally can be cited as precedent and are considered good law, but the tie prevents this decision from being precedential. NOTE: The nature of per curiam decisions may ...
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Special Education Law 101- Part II
2007-10-10 18:16:00
As explained in a previous post, I have decided to post a series of Special Ed Law 101 articles to give those outside the SpEd (special education) circle a better chance of understanding what we mean and to get more people hooked on this ever-growing field.Special Ed Law 101- Part IIThe Requirement of LRE (least restrictive environment)In addition to the requirement of FAPE, which was discussed in a previous post, the IDEA also requires that to the “…maximum extent appropriate, children with disabilities … are educated with children who are not disabled, and special classes, separate schooling or other removal of children with disabilities from the regular education environment occurs only when the nature or severity of the disability of a child is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily. IDEA, Section 612(a)(5). See, 34 C.F.R. Sections 300.114 to 300.119. This is known as "LRE."The Supreme C...
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Oral Arguments at the U. S. Supreme Court
2007-10-02 17:24:00
I was able to attend the oral argument at the U. S. Supreme Court yesterday in the IDEA case of Board of Education of City of New York v. Tom F., Case No. 06-637. Despite my many years practicing law, I am always awestruck when I enter that Courtroom. The highest court in the land does an impressive job of creating a special atmosphere.When the oral argument began, Justice Kennedy left the Courtroom. Apparently he recused himself from the case and will not take part in the decision. The most active questioners were Justices Alito, Scalia and Chief Justice Roberts. Souter and Ginsburg asked a few questions, and Bryer, Stevens only asked about one area each. Thomas said nothing, although at one point he and Bryer had a very polite private conversation for few moments. I was more surprised by their civility than anything.The thrust of the questions from Alito, Scalia and Roberts to the school district attorney concerned what purpose could be served by reading the statute to mea...
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U. S. Supreme Court to Hear Another Special Education Case
2007-09-25 03:15:00
The U. S. Supreme Court will hear oral arguments in yet another special education case on opening day of the new term, October 1st- the first Monday in October. The case is BOARD OF EDUCATION OF CITY OF NEW YORK V. TOM F., Docket No. 06-637 .The issue presented is whether the parents of a child with a disability who has never received special education from a public school district may receive reimbursement for a unilateral placement of the child in a private school after denial of FAPE by the public school district. The case is an appeal from the decision of the US Circuit Court of Appeals for the Second Circuit holding that such reimbursement was an appropriate remedy, 106 LRP 48499 (2d Cir. August, 2006).The Solicitor General, acting for the Justice Department, has filed a brief on behalf of the parent/student. Numerous groups have filed amicus briefs on behalf of both parties. Among the amicus briefs for the school district were those filed by the National School Boards Associat...
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Thanks For Your Blogger's Choice Award Votes
2007-09-25 03:00:00
I thank the many of you who have voted for this blog as best education blog and best business blog for the blogger's choice awards. We are now tenth and tied for tenth in these two categories for these prestigious awards.If you'd like to vote for this blog please register at http://www.bloggerschoiceawards.com/They' ll send you an email and you can then vote.While you are there, you'll also find a number of other categories full of interesting blogs.
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Beware the Resolution Session- Part II
2007-09-12 03:20:00
In a previous post, I described the new requirement of a resolution session where a parent files a due process hearing complaint and the anticipated problems in the area of the apparent lack of confidentiality. This post discusses some other odd angles of the new resolution session.Interestingly the “buyer’s remorse” provision that provides the parties with three days to void a settlement agreement that results from a resolution session has no counterpart in the section concerning mediation. A situation will likely arise in which a party who has voided, or attempted to void, a mediation agreement within three days after it is signed by calling it a “resolution session agreement.” OSEP, the Office of Special Education Programs- the part of the federal Department of Education that oversees special education, refused to enact a regulation requested by commenters that would require parents to be notified orally and in writing that either party has the right to void a resol...
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Special Education Law 101 - Part I
2007-09-05 21:19:00
A recent comment asked what "FAPE" and "IEP" mean. This is a good question. At a recent conference a success story former special education student told the group, "You all speak in alphabet soup." It is a tough habit to break, but the criticism is valid. As a result I decided to post a series of Special Ed Law 101 articles to give those outside the SpEd (special education) circle a better chance of understanding what we mean. Special Ed Law 101- Part IThe primary source of special education law is the federal Individuals with Disabilities Education Act, 20 U.S.C. Section 1400, et. seq., hereafter sometimes referred to as “IDEA.” (NOTE: many people refer to the sections of the act as beginning with section 600. Thus “Section 615” would be found at 20 U.S.C. Section 1415, etc.) The regulations promulgated by the United States Department of Education to implement the IDEA are found at 34 C.F.R. Part 300. The basic requirement of the ID...
Bullying- New Hot Button Issue
2007-09-03 21:15:00
(In response to a request, I am repeating this post which originally appeared on July 24, 2007.)Bullying is the hottest of hot button issues in special education law.Generally the claim of the parent is that the student cannot receive the benefit of his IEP if he is being bullied. Bullying is a growing problem that is starting in earlier grades and lasting longer. (San Diego Tribune, 7/9/07). Courts and hearing officers are beginning to hold that disability-based harassment may result in a denial of FAPE. In Shore Regional High Sch Bd. of Educ v. P.S. 41 IDELR 234, 381 F.3d 194, (3d Cir. 8/30/04), the Third Circuit held that the school district’s failure to stop bullying may constitute a denial of FAPE. Bullies constantly called the student names, threw rocks and hit him with a padlock. Despite repeated complaints, the bullying continued and the student eventually attempted suicide. See also, Preschooler II v. Clark County Sch Bd of Trustees 47 IDELR 151, 479 F.3d 1175 (9th Cir. 3...
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