Legal standards for an appropriate education in the post-Rowley era.

Legal standards for an appropriate education in the post-Rowley era. * The Individuals with Disabilities Education Act This article or section is currently being developed or reviewed.Some statements may be disputed, incorrect, , biased or otherwise objectionable. (IDEA),originally titled the Education for All Handicapped Children Act The Education for All Handicapped Children Act (sometimes referred to using the acronyms EAHCA or EHA, or Public Law (PL) 94-142) was enacted by the United States Congress in 1975. (EHCA),guarantees all students with disabilities a free appropriate publiceducation. Almost immediately after its passage in 1975, schoolofficials, parents of students with disabilities, and law professorsbegan to speculate about what constituted an "appropriate"education (McCarthy & Deignan, 1982). The implementing regulationsthat accompanied that Act provided little guidance except to define afree appropriate public education as: . . . special education and related services which: (a) Are provided at public expense, under public supervision and direction, and without charge. (b) Meet the standards of the State educational agency, . . . (c) Include preschool, elementary school, or secondary school education in the State involved, and (d) Are provided in conformity with an individualized in��di��vid��u��al��ize?tr.v. in��di��vid��u��al��ized, in��di��vid��u��al��iz��ing, in��di��vid��u��al��iz��es1. To give individuality to.2. To consider or treat individually; particularize.3. education program which meets the requirements [of these regulations]. (Code of Federal Regulations The New Deal program of legislation enacted during the administration of President franklin rooseveltestablished a large number of new federal agencies, which generated a shapeless and confusing mass of new regulations. , [section] 300.4) The state and federal courts were quickly called upon to define theterm "appropriate" (O'Hara, 1985). School districts andparents of students with disabilities had different ideas about whatconstituted an appropriate program for children with disabilities.Parents had fought long and hard for the rights contained in the IDEAand were not inclined to accept a minimal level of services for theirchildren. Early courts determined that the term "appropriate" didnot mean "best," but that the educational program providedmust be one that was individually tailored to meet the child'sspecific special education needs (Springdale School District v. Grace,1981; Rettig v. Kent City School District, 1981). Some courts alsodeclared that even the existence of a better program did not necessarilyrender a given program "inappropriate" (Buchholtz v. Iowa,1982; Age v. Bullitt County Public Schools, 1982). The courts also indicated that when a school district developed anindividualized education program In the United States an Individualized Education Program, commonly referred to as an IEP, is mandated by the Individuals with Disabilities Education Act (IDEA). In Canada an equivalent document is called an Individual Education Plan. (IEP IEPIn currencies, this is the abbreviation for the Irish Punt.Notes:The currency market, also known as the Foreign Exchange market, is the largest financial market in the world, with a daily average volume of over US $1 trillion. ) for a student with disabilities,it was to be developed to meet the needs of the student rather thanthose of the school district (Campbell v. Talladega County Board ofEducation, 1981; Gladys J. v. Pearland Independent School District,1981). Although the courts emphasized that the placement of the studentwith disabilities must be suited to that chid's unique needs, minorimperfections in an IEP did not necessarily render it inappropriate(Osborne, 1988; Thomas, 1986). During the first few years the IDEA was in force, the courts madeseveral landmark decisions that helped to clarify exactly what was meantby an appropriate education. A majority of the courts reasoned thatappropriate meant more than simple access to educational programs butfell somewhere short of the best that could possibly be provided(O'Hara, 1985). In 1980 litigation An action brought in court to enforce a particular right. The act or process of bringing a lawsuit in and of itself; a judicial contest; any dispute.When a person begins a civil lawsuit, the person enters into a process called litigation. arose in the district court forthe eastern district of New York New York, state, United StatesNew York,Middle Atlantic state of the United States. It is bordered by Vermont, Massachusetts, Connecticut, and the Atlantic Ocean (E), New Jersey and Pennsylvania (S), Lakes Erie and Ontario and the Canadian province of that would eventually become the firstIDEA case to be heard by the U.S. Supreme Court. THE SUPREME COURT'S STANDARD OF APPROPRIATENESS Board of Education of Hendrick Hudson Central School District Hendrick Hudson Central School District is located in Westchester County, New York and is made up of five schools: three elementary schools, one middle school, and one high school. v.Rowley (1982) provided the Supreme Court with the opportunity tointerpret the term "appropriate placement." The studentinvolved in this litigation was deaf and therefore was entitled toservices under the IDEA. She had minimal residual hearing and was anexcellent lipreader. When she entered the public school system, she wasplaced in a regular kindergarten class on a trial basis to determinewhat services she would need. Several of the school's staff tooksign language courses and a teletype machine was installed tocommunicate with the student's parents who were also deaf. She wasalso provided with a sign language interpreter; however, at the end ofthe trial period the interpreter reported that these services were notneeded. The IEP written for her first-grade year called for regular classplacement, an FM hearing aid that would amplify words spoken by herteacher and classmates Classmates can refer to either: Classmates.com, a social networking website. Classmates (film), a 2006 Malayalam blockbuster directed by Lal Jose, starring Prithviraj, Jayasurya, Indragith, Sunil, Jagathy, Kavya Madhavan, Balachandra Menon, ... , 1 hour (hr) per day of instruction from a tutorfor the deaf, and 3 hr per week of speech therapy. Her parents agreed tothe IEP but requested the addition of a sign language interpreter. Whenthat request was denied, they requested a due process hearing. The school district prevailed in the administrative hearings;however, the district court found that although the student performedbetter than average, she understood much less of what went on in theclassroom than she would have if she were not deaf. The court held thatthe school district's IEP was inappropriate because it did notprovide the student with an opportunity to achieve her full potentialcommensurate with the opportunity provided to nondisabled children. TheSecond Circuit Court of Appeals affirmed the district court'sruling. The issue before the Supreme Court basically concerned the level ofservices that must be provided for an IEP, and consequently a specialeducation placement, to be considered appropriate. On a split decision,the Court reversed the appeals court, holding that the lower courts haderred in determining that the level of services must be such that thepotential of the child with disabilities is maximized commensurate withthe opportunity provided to nondisabled students. The majority opinion,written by Justice Rehnquist, stated that: Insofar in��so��far?adv.To such an extent.Adv. 1. insofar - to the degree or extent that; "insofar as it can be ascertained, the horse lung is comparable to that of man"; "so far as it is reasonably practical he should practice as a State is required to provide a handicapped child with a "free appropriate public education" we hold that it satisfies this requirement by providing personalized per��son��al��ize?tr.v. per��son��al��ized, per��son��al��iz��ing, per��son��al��iz��es1. To take (a general remark or characterization) in a personal manner.2. To attribute human or personal qualities to; personify. instruction with sufficient services to permit the child to benefit educationally from that instruction. Such instruction and services must be provided at public expense, must meet the State's educational standards, must approximate the grade levels used in the State's regular education, and must comport See COM port. with the child's IEP. In addition, the IEP, and therefore the personalized instruction, should be formulated in accordance with the requirements of the Act and, if the child is being educated in the regular classrooms of the public education system, should be reasonably calculated to enable the child to achieve passing marks and advance from grade to grade. (102 S. Ct. 3049). The Court ruled that the sign language interpreter was not requiredbecause the student was performing better than average and was receivingpersonalized instruction that was reasonably calculated to meet hereducational needs. The Court, in examining the language of the Act and its legislativehistory, found that several other provisions are pertinent todetermining whether a proposed IEP is appropriate. Specifically, thespecial education program must be provided in the least restrictiveenvironment As part of the U.S. Individuals with Disabilities Education Act, the least restrictive environment is identified as one of the six principles that govern the education of students with disabilities. [IDEA [section] 1412(5)] and that related, or supportive,services that may be required to assist the child in benefiting from thespecial education program must be provided [IDEA [section] 1401(17)]. The Supreme Court's ruling was criticized by advocates for thedisabled because it established a precedent for providing disabledstudents with only a basic floor of opportunity rather than a level ofservices that would allow them to receive an equal educationalopportunity. It was also criticized for not providing a clearerdefinition of "appropriate." However, the decision wassignificant because it established that children with disabilities wereentitled to a level of services sufficient for them to benefit fromeducation (Flygare, 1982, Anthony, 1982). THE LOWER COURTS' REACTION TO ROWLEY The initial lower court reaction to Rowley was to hold that an IEPwas appropriate if some educational benefit was obtained by the student.One court stated that it would not interfere where the school districtwas providing an education that was of some benefit to the student andwas using a minimally acceptable approach (Lang v. Braintree, 1982).Most courts adopted the view that once a school district was able toshow that their proposed IEP was reasonably calculated to result in someeducational benefit, regardless of how minimal that benefit was, thecourt was required to approve it. The courts were not inclined to becomeentrenched en��trench? also in��trenchv. en��trenched, en��trench��ing, en��trench��esv.tr.1. To provide with a trench, especially for the purpose of fortifying or defending.2. in debates over the best methodology or even which of twoalternative placements would be better (Doe v. Lawson, 1984; Karl v Karl V is an opera, described as a B��hnenwerk mit Musik ('stage work with music') by Ernst Krenek, his opus 73. The German libretto is by the composer. .Board of Education, 1984; Manuel R. v. Ambach, 1986). Thus, under Rowleythe lower federal courts adhered to the reasoning that all Congressintended in passing the IDEA was to provide students with disabilitiesaccess to educational programs. However, the lower courts have also considered the other provisionsof the IDEA alluded to in Rowley to determine whether a given IEP wasappropriate. Most significantly, the courts have given due weight to theleast restrictive environment mandate. The IDEA's regulationsprovide that students with disabilities are to be educated withnondisabled students to the "maximum extent appropriate" andshould be removed from a regular classroom setting only when they cannotbe satisfactorily educated in that environment (Code of FederalRegulations, [section] 300.550). The courts have held that althoughmainstreaming does not have to be provided in every case, it must beprovided to the maximum extent appropriate and that a placement that mayseem better for academic reasons may be inappropriate due to the failureto provide mainstreaming (Roncker v. Walter, 1983). Recognizing thatsocialization socialization/so��cial��iza��tion/ (so?shal-i-za��shun) the process by which society integrates the individual and the individual learns to behave in socially acceptable ways. so��cial��i��za��tionn. is also very important for children with disabilities, onecourt held that a mainstream setting was appropriate because socialvalues would be enhanced even though some educational quality would belost (Bonadonna v. Cooperman, 1985). The courts have, however,recognized that a mainstream setting is not appropriate for all students(Matthews v. Campbell, 1979; St. Louis v Louis V, king of FranceLouis V(Louis the Sluggard), c.967–987, last French king of the Carolingian dynasty; son of King Lothair. His father had him crowned in 979, but he did not become king until Lothair's death in 986. . Mallory, 1984; Board ofEducation v. Diamond, 1986; Osborne, 1990). The courts have also held that in some situations related servicesare required in order for the student to receive educational benefitfrom a special education program. These decisions are based on what hasbecome known as the related services mandate of the IDEA (Code ofFederal Regulations, [section] 300.13). If the related services arenecessary for educational benefit to be conferred, then an IEP would notbe appropriate if those services were not provided. Some of the relatedservices that courts have ordered include psychotherapy psychotherapy,treatment of mental and emotional disorders using psychological methods. Psychotherapy, thus, does not include physiological interventions, such as drug therapy or electroconvulsive therapy, although it may be used in combination with such methods. , transportation,health services health servicesManaged care The benefits covered under a health contract , occupational therapy, and physical therapy (Osborne,1985; Thomas, 1984). The First Circuit Court of Appeals, however, has held that astudent with severe disabilities need not demonstrate an ability tobenefit from a special education program in order to be eligible forservices. In holding that the IDEA's mandates apply even tostudents with severe disabilities, the court defined education in broadterms. The court stated that education encompasses a wide spectrum oftraining and includes instruction in even the most basic life skills(Timothy W. v. Rochester, New Hampshire Rochester is a city in Strafford County, New Hampshire, United States. As of the 2000 census, the city population was 28,461, the largest in New Hampshire's Seacoast region. School District, 1989). IS TRIVIAL BENEFIT ENOUGH? Although it has generally been held that in passing the IDEA,Congress intended only to provide disabled children with a basic floorof opportunity, some courts have held that Rowley's "someeducational benefit" standard requires more than just trivialprogress. In Hall v. Vance County Board of Education (1985) the FourthCircuit Court of Appeals found that Rowley allowed the courts to make acase-by-case determination of what substantive standards met thecriteria that an IEP was to be reasonably calculated to enable thestudent to receive educational benefits. In this case, test scoresindicated that minimal progress had been made. In light of thestudent's intellectual potential the court found minimal results tobe insufficient. The court stated that Congress certainly did not intendfor a school system to provide a program that produced only trivialacademic advancement. The Third Circuit of Appeals in Board of Education v. Diamond(1986) held that Rowley's mandate that to be appropriate an IEPmust confer educational benefit on the student required a plan likely toproduce progress, not trivial educational advancement. That same courtin Polk v. Central Susquehanna Intermediate Unit 16 (1988) ruled thatthe IDEA calls for more than just trivial educational benefit. The courtfound that Congress intended to provide children with disabilities withan education that would confer meaningful benefit. EFFECT OF STATE STANDARDS Under the IDEA's scheme, any state receiving funds under theAct is required to pass legislation that would bring the state intoconformity with the federal requirements (IDEA [section] 1412). Althoughthe special education laws and regulations in most states define anappropriate placement in a fashion similar to the federal standard,several states have established a higher standard of appropriatenessthan that set out in the IDEA, as interpreted by Rowley. The courts haveheld that these higher state standards are controlling within their ownjurisdictions. In a decision handed down less than 1 month after Rowley,the Court of Appeals of North Carolina North Carolina,state in the SE United States. It is bordered by the Atlantic Ocean (E), South Carolina and Georgia (S), Tennessee (W), and Virginia (N).Facts and FiguresArea, 52,586 sq mi (136,198 sq km). Pop. held that the Rowley decision didnot control their interpretation of the state standard (Harrell v.Wilson County Wilson County is the name of four counties in the United States: Wilson County, Kansas Wilson County, North Carolina Wilson County, Tennessee Wilson County, Texas Schools, 1982). Under the North Carolina statute in forceat the time the case arose, the court found that a student withdisabilities should be provided an opportunity to achieve his or herpotential commensurate with the opportunity provided to other students.Since the school district had also met the higher standard, its proposedIEP was upheld. The Third Circuit Court of Appeals held that state standards wereautomatically incorporated into the federal statute since one of therequirements of an appropriate education under the IDEA was that it mustmeet "the standards of the state educational agency" [IDEA[section] 1401 (18)(B)]. Using that mandate, the court found in Geis v.Board of Education (1985) that any state standards that went beyond theminimum standards of the IDEA were incorporated into the federal law,and the courts were authorized to enforce the higher New Jerseystandards under their federal question jurisdiction. A year later thatsame court interpreted the New Jersey standard to require educationalservices according to according toprep.1. As stated or indicated by; on the authority of: according to historians.2. In keeping with: according to instructions.3. how the student can best achieve success inlearning (Board of Education v. Diamond, 1986). Approximately 2 weeks after the Third Circuit's decision inGeis, the First Circuit made a similar ruling in David D. v. DartmouthSchool Committee (1985). The appeals court held that the district courthad correctly applied Massachusetts's more stringent state standardthat an IEP should be designed to maximize the potential of a child withdisabilities in order to be appropriate. The appeals court ruled thatwhere a state has chosen to provide greater benefits to children withdisabilities, the courts are required to incorporate the state'sstandards into the Act when determining the appropriateness of the IEP.It found that Congress did not intend to reduce state standards to thefederal minimum. The U.S. Supreme Court allowed that decision to standby denying certiorari certiorariIn law, a writ issued by a superior court for the reexamination of an action of a lower court. The writ of certiorari was originally a writ from England's Court of Queen's (King's) Bench to the judges of an inferior court; it was later expanded to include writs . Michigan's special education legislation also requires thedevelopment of an IEP that is designed to develop the maximum potentialof the child with disabilities according to a court of appeals in thatstate (Nelson v. Southfield, 1986). Again, the state court held that themore rigorous standard was incorporated into the IDEA by reference. Thecourt noted that the term "maximum potential" was not definedbut that some limitation was required. A federal district court, inreviewing state courts' definitions, determined that "maximumpotential" did not mean utopian or the best education possible(Barwacz v. Michigan, 1988). Noting that the proposed IEP provided foreducation in the least restrictive environment, the court placed theburden of proof on the plaintiff to show that the proposed IEP did notmeet Michigan's higher standard. IMPLICATIONS Conventional theory in the field of special education holds thateach child with a disability is to be treated as an individual and thatto be successful an instructional program must be designed with thatchild's unique abilities and needs in mind. The courts also havefound that each case brought before them on the basis of the IDEA mustbe decided on its individual merits. Although the courts must interpretand apply the law according to proscribed PROSCRIBED, civil law. Among the Romans, a man was said to be proscribed when a reward was offered for his head; but the term was more usually applied to those who were sentenced to some punishment which carried with it the consequences of civil death. Code, 9; 49. standards and legal precedent,some allowance must be made for the unique individual aspects of eachfactual situation. The Supreme Court's definition of an appropriateeducation in the Rowley case helped to clarify some of the ambiguityeducators found in the law, but it did not provide the lower courts withan all-inclusive formula for deciding whether a given IEP wasappropriate. Given the variety of disabling dis��a��ble?tr.v. dis��a��bled, dis��a��bling, dis��a��bles1. To deprive of capability or effectiveness, especially to impair the physical abilities of.2. Law To render legally disqualified. conditions covered by theAct, and the varying degrees of severity within each category ofdisability, to do so would have been an impossible task. Thisimpossibility ImpossibilitySee also Unattainability.belling the catmouse’s proposal for warning of cat’s approach; application fatal. [Gk. Lit. was clearly recognized by the Court and it is highlyunlikely that the Court ever intended to establish a single test thatwould be used to judge the appropriateness of all IEPs. Initially, the lower courts applied the Rowley standard in a strictmanner. They examined the IEP and the procedural history of the case todetermine if the IEP had been developed according to the IDEA'smandates. Secondly, they examined the testimony of expert witnesses andgave due weight to the decisions of impartial hearing officers todetermine if the IEP would result in some kind of educational benefit.As long as the first prong of this standard was met and the schooldistrict was able to show that some educational benefit was likely to begained by the student, no matter how minimal, the IEP was usuallyupheld. The lower courts also considered additional provisions of the IDEAin determining whether or not a given IEP was appropriate, such as theleast restrictive environment mandate, the related services mandate, andthe requirement that an IEP meet state educational standards. In thisrespect the courts have extended the two-prong Rowley standard toinclude other factors that are clearly spelled out in the IDEA ascomponents of an appropriate education and which were alluded to by theSupreme Court. This has not necessarily expanded the Court'sdefinition of an appropriate education, but rather, it has applied thatdefinition to the unique aspects of a given factual situation as theCourt itself contemplated. Later courts, faced with difficult factual situations, determinedthat "some" educational benefit meant more than just"trivial" benefit. These courts held that the educationalbenefit conferred must be "meaningful." This interpretationappears to be an expansion of the Rowley standard; but it's onethat is clearly in line with both Congress's and the highCourt's intent. In Rowley the high Court stated: It would do little good for Congress to spend millions of dollars in providing access to a public education only to have the handicapped child receive no benefit from that education. (102 S. Ct. 3048) It is incomprehensible that Congress would spend millions ofdollars to achieve only minimal educational progress for thenation's children with disabilities. The educational benefit to beobtained must be meaningful. Again, however, we have a question ofsemantics: What is meaningful? Educators and parents will not get asingle formula that can be applied to all cases. Each case must bedetermined on its own merits. The courts appear to have recognized thisfact and are attempting to make decisions that are equitable in light ofthe particular circumstances of the case. Lower courts today are notinterpreting Rowley as strictly as they were in the years immediatelyfollowing the decision. This is welcome turn of events as it isconsistent with both educational and legal philosophy. Special educators need to be aware of the court's recent trendto apply the IDEA's standards for appropriate educational placementin a light more favorable to the student with disabilities. When aschool district's IEP is challenged, school officials should beprepared to show that it was designed to result in a degree ofeducational advancement that is consistent with the student'soverall abilities. For students who are educated predominantly in themainstream, this means receiving passing grades and advancing from gradeto grade as the Supreme Court suggested in Rowley. For students withmore severe disabilities, progress towards greater self-sufficiency andindependence would be more reasonable. In order to show that an IEP is reasonably calculated to provide adisabled student with meaningful educational benefit, school officialswill need to provide evidence of what the student can reasonably beexpected to achieve. Then they will need to show that his or her IEP,and the educational program it calls for, is designed to permit thestudent to progress according to reasonable expectations. Of course whatis reasonable is a highly individual matter and will vary from studentto student. One court has suggested that a given student's progresscan be compared to the progress of other students with similardisabilities. The court also emphasized the importance of consideringpast progress in predicting future progress (School Board of CampbellCounty There are five counties in the U.S. named Campbell County: Campbell County, Wyoming Campbell County, Virginia v. Beasley, 1989). In this respect, the courts are often inclinedto accept the expert testimony Testimony about a scientific, technical, or professional issue given by a person qualified to testify because of familiarity with the subject or special training in the field. of experienced educators. Judgesgenerally recognize that they do not have the expertise to makedecisions regarding educational methodology. In the absence of highlypersuasive evidence to the contrary, judges will generally defer to theschool authorities. Obviously school districts in those few states that haveestablished a standard of appropriateness higher than the federalstandard must consider other factors as well. These higher statestandards also vary in their requirements; a state-by-state discussionis beyond the scope of this article. School officials in those statesthat have set a higher standard are advised to become familiar withadministrative hearing administrative hearingn. a hearing before any governmental agency or before an administrative law judge. Such hearings can range from simple arguments to what amounts to a trial. There is no jury, but the agency or the administrative law judge will make a ruling. decisions for further guidance. Judges have been cautioned by the Supreme Court not to substitutetheir judgment on educational matters for that of the educationalauthorities (Board of Education v. Rowley, 1982). The court should notassume the role of a super school board; rather, the role of the courtis to ensure that the decisions made by educators are consistent withthe mandates of the law. The recent trend of some lower courts toward aless strict interpretation of Rowley is reasonable and should not be acause for concern for educators who want to do what is right. As hasrecently been observed: The overriding theme of the EHCA [IDEA] is that all placement and programming decisions on handicapped students must be made on an individualized basis and must be made on the basis of information gathered from a variety of sources. If an administrator makes a decision on those bases, follows the procedures mandated by the EHCA, and makes the decision in good faith with the best interests of the child and school system in mind, that decision has a reasonable chance of being upheld. (Osborne, 1988) REFERENCESAge v. Bullitt County Public Schools, 673 F.2d 141,3 Ed. Law Rep. 303(6th Cir. 1982). Anthony P. (1982). A critique of Rowley by a specialeducator. Education Law Reporter, 6, 867-874. Barwacz v. MichiganDepartment of Education, 681 F. Supp. 427, 46 Ed. Law Rep. 98 (W.D.Mich. 1988). Board of Education of East Windsor Regional School District The East Windsor Regional School District is a comprehensive public school district in Mercer County, New Jersey which serves students in Kindergarten through 12th grade. Students come from East Windsor Township (4,061 students from a 2000 census population of 24,919) and v. Diamond, 808 F.2d 987, 36 Ed. Law Rep. 1136 (3rd Cir. 1986). Board ofEducation of Hendrick Hudson Central School District v. Rowley, 458,U.S. 176, 102 S.Ct. 3034, 73 L.Ed.2d 690, 5 Ed. Law Rep. 34 (1982).Bonadonna v. Cooperman, 619 F. Supp. 401, 28 Ed. Law Rep. 430 (D.N.J.1985). Buchholtz v. Iowa Department of Public Instruction, 315 N.W.2d789, 2 Ed. Law Rep. 848 (Iowa 1982). Campbell v. Talladega County Boardof Education, 518 F. Supp. 47 (N.D. Ala. 1981). Code of FederalRegulations, 34, 300 et seq et seq.(et seek) n. abbreviation for the Latin phrase et sequentes meaning "and the following." It is commonly used by lawyers to include numbered lists, pages or sections after the first number is stated, as in "the rules of the road are found in Vehicle Code . David D. v. Dartmouth School Committee, 775F.2d 411, 28 Ed. Law Rep. 70 (1st Cir. 1985). Cert. den'd sub nom.Massachusetts Department of Education v. David D., 106 S.Ct. 1790, 31Ed. Law Rep. 725 (1986). Doe v. Lawson, 579 F. Supp. 1314, 16 Ed. LawRep. 498 (D. Mass. 1984). Flygare, T. (1982). Supreme Court holds thatP.L. 94-142 does not require sign-language interpreters for deafstudents. Phi Delta Kappan, 64(1), 62-63. Geis v. Board of Education ofParsippany-Troy Hills, 774F.2d 575, 27 Ed. Law Rep. 1093 (3d Cir. 1985).Gladys J. v. Pearland Independent School District, 520 F. Supp. 869(S.D. Tex. 1981). Hall v. Vance County Board of Education, 774 F. Supp.629, 27 Ed. Law Rep. 1107 (4th Cir. 1985). Harrell v. Wilson CountySchools, 293 S.E. 2d 687, 5 Ed. Law Rep. 658 (N.C.Ct. App. 1982).Individuals with Disabilities Education Act (1975), United States Code Noun 1. United States Code - a consolidation and codification by subject matter of the general and permanent laws of the United States; is prepared and published by a unit of the United States House of RepresentativesU. S. ,20. [section] 1401 et seq. Karl v. Board of Education, 736 F.2d 873 Ed.Law Rep. 310 (2d Cir. 1984). Lang v. Braintree School Committee, 545 F.Supp. 1314, 16 Ed. Law Rep. 498 (D. Mass. 1982). Manuel R. v. Ambach,635 F. Supp. 791, 33 Ed. Law Rep. 203 (E.D. N.Y. 1986). Matthews v.Campbell, 551 EHLR EHLR East Hayling Light RailwayEHLR Education for the Handicapped Law Reporter (now Individuals with Disabilities Law Reporter)EHLR Edge Hill Light Railway (UK)264 (E.D. Va. 1979). McCarthy, M., & Deignan, P.(1982). What legally constitutes an adequate public education?Bloomington, IN: Phi Delta Kappa Phi Delta Kappa is an international professional organization for educators. JournalThe Phi Delta Kappan is a professional journal for education, published by Phi Delta Kappa. Educational Foundation. Nelson v.Southfield Public Schools, 384 N.W.2d 423, 31 Ed. Law Rep. 567 (Mich.Ct. App. 1986). O'Hara, J. (1985). Determinants of an appropriateeducation under 94-142. Education Law Reporter, 27, 1037-1045. Osborne,A. (1985). Recent judicial developments affecting the EHCA'srelated services mandate. Education Law Reporter, 26, 579-584. Osborne,A. (1988). Complete legal guide to special education services. WestNyack, NY: Parker Publishing Co. Osborne, A. (1990). When has a schooldistrict met its obligation to mainstream handicapped students under theEHA EHA European Hematology AssociationEHA Economic History AssociationEHA Emmanuel Hospital AssociationEHA Education for All Handicapped Children Act of 1975EHA Empty Homes AgencyEHA English Hockey AssociationEHA Electrohydrostatic Actuator ? Education Law Reporter, 58, 445-455. Polk v. Central SusquehannaIntermediate Unit 16,853 F.2d 171, 48 Ed. Law Rep. 336 (3d Cir. 1988).Rettig v. Kent City School District, 539 F. Supp. 768, 4 Ed. Law Rep.1083 (N.D. Ohio 1981), aff'd in pt. vac'd and rem'd inpt. 720 F.2d 463, 14 Ed. Law Rep. 445 (6th Cir. 1983), on rem'd(unpublished opinion), rev'd 788 F.2d 328, 31 Ed. Law Rep. 759 (6thCir. 1986), cert. den'd 106 S.Ct. 3297, 33 Ed. Law Rep. 35 (1986).Roncker v. Walter, 700 F.2d 1058, 9 Ed. Law Rep. 827 (6th Cir. 1983).St. Louis Developmental Disabilities Center v. Mallory, 591 F. Supp1416, 20 Ed. Law Rep. 133 (W.D. Mo. 1984). School Board of CampbellCounty v. Beasley, 380 S.E.2d 884, 54 Ed. Law Rep. 1363 (Va. 1989).Springdale School District v. Grace, 656 F. Supp. 300 (8th Cir. 1981),vac'd and rem'd 102 S.Ct. 3504 (1982), on rem'd 693 F.2d41, 7 Ed. Law Rep. 509 (8th Cir. 1982). Thomas S. (1984). Relatedservices under the Education of the Handicapped Act. Education LawReporter, 21, 447-451. Thomas, S. (1986). Legal issues in specialeducation. Topeka, KS: National Organization on Legal Problems ofEducation. Timothy W. v. Rochester, New Hampshire School District, 875F.2d 954, 54 Ed. Law Rep. 74 (1st Cir. 1989). ALLAN G. OSBORNE, JR. (CEC (Central Electronic Complex) The set of hardware that defines a mainframe, which includes the CPU(s), memory, channels, controllers and power supplies included in the box. Some CECs, such as IBM's Multiprise 2000 and 3000, include data storage devices as well. MA Federation) is on the Special Education Staff of the Quincy PublicSchools The Quincy Public Schools are located at Quincy, Massachusetts. HistoryThe Quincy Public Schools first superintendent was Francis W. Parker. He has an elementary school, F. W. Parker School, named after him. in Quincy, Massachusetts Quincy is a city in Norfolk County, Massachusetts. It bears the nicknames "The City of Presidents," "City of Legends," "Birthplace of the American Dream."[1] A major part of Metropolitan Boston, Quincy is a member of Boston's Inner Core Committee for the Metropolitan .