Sacramento City Unified School District V. Rachel H. 1994 U. S Sacramento City Unified School District V. Rachel H. 1994 U.S. 9th Court of Appeals Brooke Kobren

Background Information Rachel Holland was a student in the Sacramento City Unified School District Rachel had a mental retardation, had a low IQ (44), and attended a variety of special education programs in the district from 1985-1989. Not only did Rachel attend these special education programs, at the same time she spent a small part of each day in a regular classroom from 1987-1989. However, she was only integrated in a regular classroom for only an hour per each day. Rachel’s parents requested full time placement in a regular classroom for the 1989 school year. The district denied the request but thought out an alternative plan. The plan was for Rachel to spend half of her time in her special education classes, and the other half of her time in the regular classroom. She would take all of her core academic classes in her special education class, and her electives like art, music, lunch, and recess would be in a regular classroom. Believing that Rachel would benefit being put in a full time placement in a regular classroom; her parents appealed the districts planning decision to a California special education hearing officer. In the meantime, Rachel’s parents enrolled her in a private school instead, where she was placed in a regular kindergarten class. Rachel progressed greatly during her time in the regular classroom. The hearing found that Rachel had benefitted from being in the regular kindergarten class, especially due to the beneficiaries received through imitating and mimicking non-disabled peers. Subsequently, the hearing officer ordered Rachel’s placement in a full time mainstream setting. However, the school district quickly filed an appeal in federal district court.

Court Case The court was to determine the final decision of the hearing officer applies with the IDEA (Individuals with Disabilities Education Improvement Act of 2004) “all children with disabilities are entitled to a free appropriate public education to meet their unique needs.” On March 2, 1992, the court once again ruled in favor of the Holland’s. Judge David E. Levi identified four factors in determining placement: The educational benefits available in the regular classroom; The non-academic benefits of interaction between a student with disabilities and those without disabilities; The impact of the student with disabilities on the teacher and other children in the regular classroom; and The cost of supplementary aids and services requested for mainstreaming the student In these factors the judge ruled that Rachel be placed is a regular classroom. He identified a social benefit of inclusion knowing that a proposed special education program would mark Rachel as an outsider and he also gave great weight to the testimony of Rachel’s general education teacher who said she was a full member of the second grade class. Following this decision, the school district appealed again, but to the Supreme Court but the court refused to hear the case.

Why it Matters Supreme Court’s refusal to hear the case “signals an end to the historic segregation and isolation of children with disabilities in the American public school system. By upholding the 9th Circuit Court of Appeal's decision the principles established in Brown v. Board of Education over four decades ago now apply to children with disabilities.” –Diana Lipton, DREDF attorney This court case was a landmark for inclusion in schools. It upheld the IDEA and made it feasible for a disabled student to be in a regular classroom, then they should be. This refers that providing students with the Least Restrictive Environment (LRE) are engaged to learn. The IDEA specifically requires states and consequently school boards to set up procedures ensuring that children with disabilities are educated to the maximum extent appropriate with children who do not have disabilities. This case was also important because it sets the precedence using the four factors listed by the judge. Those four factors are now referenced placing students with disabilities in the educational program.

My Opinion I was in favor of the ruling. There was substantial evidence proven that Rachel benefited from being included in a regular classroom. Additionally, it was sited in the original hearing that the school districts half and half plan required Rachel to be moved at least six times during the day which is very destructive to her education. The courts ruling with in line with the IDEA especially when it comes to the LRE. Even though I agree with the courts decision, I could see where the school district was coming from. They also wanted what was best for Rachel. They just thought more guidance and assistance would be better suited for Rachel in an education classroom.

Important to Educators I think it is an important case for educators to be aware of the outcome. If you ever teach someone who has disabilities, it is important to take special note of their behavior in the classroom. If the student seems to be positively interested in the class and is succeeding, then you know the student is in the least restrictive environment for them. You can base these observations on the four factors the judge laid out in the case. The case heavily relied on the statements provided from the general education teacher. This shows that observations and opinions matter. Hopefully it doesn't’t come to a court case, but it is still important for teachers to be aware of students progress in the class when it comes to discuss that child’s individualized education program (IEP) which is an unique plan made for each student with a disability. They can use this knowledge about IDEA and LRE to help create the best possible for that student.

Scenario If there is ever a time you have a student in your classroom who does have a learning disability, it is always important to think about what would be best for the student. It is not a time to think about the best or easiest for you (the teacher). The more work, you as the teacher put in, the easier it is for the student and can be a greater reward to see the progress of the student. Writing down notes is a great way to present the progress of the student instead of just a “he said/she said”. If there is written documentation, it would greatly help out the best solution for the student and something that could be presented in a court case and an IEP. Too much information is better than not enough.

Works Cited BD. OF EDUC., SACRAMENTO CITY SCHOOL D. v. HOLLAND. (n.d.). Retrieved November 7, 2017, from http://www.leagle.com/decision/19921660786FSupp874_1158/BD.%200F%20EDC.,%20SACRAMENTO%20 CITY%20SCHOOL%20D.%20v.%20HOLLAND Gruienhagen, K. A. & Steve, S. G. (1995). Least Restrictive Environment and Case Law: What the Courts Are Saying about Inclusion (pp. 1-10, Rep. No. ED386005). (ERIC Document Reproduction Service No. C304207) Individuals with Disabilities Education Act (IDEA). (n.d). Retrieved November 8, 2017 http://www.apa.org/about/gr/issues/disabilities/idea.aspx Placement Issues. (2014. March). Retrieved November 8 2017. from http://www.parentcenterhub.org/repository/placement/ Sacramento V. Rachel H. (n.d.) Retrieved November 8, 2017. from http://www.kidstogether.org/right- ed_files/rachel.htm