History of Special Education in the United States

  • The 14th Amendment

    The 14th Amendment
    The 14th Amendment states that all persons born in the United States are citizens and that no state shall deprive them of life, liberty and property and that citizens are entitled to equal protection of the law.
  • Brown v. Board of Education

    Brown v. Board of Education
    In 1954, the United States Supreme Court ruled that separate is not equal and ended racial segregation in schools. This ruling opened the door for students being segregated due to their disabilities (Yell, 2019).
  • The Civil Rights Act

    The Civil Right Act ended racial discrimination and segregation in public places and provided a framework for individuals with disabilities.
  • The Elementary and Secondary Education Act

    The ESEA provided federal funding to states for assistance in educating certain groups of students and to improve educational opportunities for these disadvantaged students (Yell, 2019).
  • PARC v. Pennsylvania

    PARC argued that all students labeled with mental retardation were not being provided with a free public education. It was ruled in favor of PARC that all students between the ages of 6 and 21 be provided with a free public education, similar to the program that their peers without disabilities receive (Yell, 2019).
  • Mills v. Board of Education

    Mills V. Board of Education argued that if students being segregated because of race is unconstitutional, then so is total exclusion of students due to disabilities. The outcome of Mills was that all students with disabilities receive a publicly supported education (Yell, 2019).
  • The Rehabilitation Act-504

    The purpose of this act was to address the discrimination of people with disabilities and it noted that any agency receiving federal funds must not discriminate against people with disabilities and must make the appropriate accommodations and modifications to provide services as it would to any other person.
  • The Education for All Handicapped Children's Act (PL 94-142)

    The Education for All Handicapped Children's Act (PL 94-142)
    In 1975, President Ford signed into law the EAHCA, which greatly increased the federal involvement in special education. Due to many students with disabilities not receiving an education or not receiving one appropriate to their needs, it required states to provide an appropriate education for students ages 3 to 18 and increased the age to 21 by 1980. It also implemented the IEP, or individualized education plan to make sure these educational needs were being met and documented (Yell, 2019).
  • Armstrong v. Kline

    Armstrong v. Kline questioned the 180 day school year rule and argued that in certain situations, the 180 day rule violated EAHCA for students with severe disabilities and emotional disturbances. This case had a significant impact on the development of ESY or extended school year, which provides educational opportunities for these students beyond the 180 days (Kraft, 2000).
  • Larry P. v. Riles

    A federal district court in California ruled that the use of standardized IQ instruments for placement into EMR classes for African American students was unlawful due to the fact that the tests contained racial and cultural bias. This was upheld by the U.S. Court of Appeals in 1986 and expanded to include IQ testing as unlawful for all African American students in determining special education placements (Yell, 2019).
  • Board of Education of the Hendrick Hudson School District v. Rowley

    The Supreme Court ruled that in some situations, it may not be appropriate for certain students with disabilities to be educated in the same environment as their peers and therefore may require alternative placement to address their needs (Yell, 2019).
  • Irving Independent School District v. Tatro

    This case questioned the requested CIC services for a student in order to be able to attend school. This led to the Supreme Court adopting a "bright-line test" for lower courts to use when addressing cases related to providing services in educational settings. If the service had to be provided by a physician, the school was not required to provide it. If it did not require a physician, then the school is required to provide these services, including medical services (Yell, 2019).
  • Burlington School Committee v. Massachusetts Department of Education

    This case occurred do to the school district not having appropriate placement and the parents pulling the child out and placing him in the appropriate private setting. The district eventually agreed to pay but did not want to reimburse because it was the parents decision, not theirs, when placing the child. The Supreme Court ruled that parents are entitled to reimbursement if they remove their child and place them in a private setting if their IEP is deemed inappropriate (Yell, 2019).
  • The Education of the Handicapped Amendments

    This act brought to light the importance of early intervention for children from birth to age 3. This Act required that states provide early intervention services to children from birth to age three (Yell, 209).
  • Honig v. Doe

    Honig v. Doe stresses that the school district should not explore long-term suspensions and expulsions of students with disabilities because of the violation of IDEA and should explore other options such as restriction of privileges and in more severe cases, a 10-day suspension, where in that time, an IEP meeting can be held and placement can be addressed. During these proceedings, the student's placement should remain unchanged (Yell, 2019).
  • Daniel R.R. v. State Board of Education

    This case emphasizes that school districts need to satisfy the least restrictive environment requirements of IDEA by addressing the following questions: 1. Can education in the general classroom with supplementary aids and services be achieved satisfactorily? 2. If a student is placed in a more restrictive setting, is the student integrated to the maximum extent appropriate? These findings have been adopted used in subsequent cases (Yell,2019)
  • The Individuals with Disabilities Education Act

    The Individuals with Disabilities Education Act of 1990, also known as IDEA, renamed EAHCA, and substituted the term disability for handicap going forward. It also promoted "people first" language and added two disability categories, autism and traumatic brain injury. It also added clarification of related services, technology and rehabilitation services. One major addition was the inclusion of transition planning and services in IEPs (Yell, 2019).
  • Americans with Disabilities Act

    This Act provided protection for individuals with disabilities against discrimination in both public and private sectors, especially in the areas of employment and public services. This act addresses the 14th amendment and how the discrimination of people with disabilities violates it. It provided a clear mandate stopping discrimination against these individuals and the standards for enforcing such mandate (Yell, 2019).
  • Board of Education in Sacramento City School District v. Rachel Holland

    This case presented the question if a child was being placed in the correct setting, as requested by her parents. The court based their decision on four factors, if there were educational benefits in the placement, if there were noneducational benefits in the placement, if others were impacted by the students presence and lastly the evaluation of the cost of such placement. The factors showed that the district could not provide proof and that she should be in general education (Yell, 2019).
  • Oberti v. Board of Education

    This case expressed the important of districts providing proof of the measures taken to support a student in the general education classroom and if so, why the student is not deemed appropriate for the setting (Yell, 2019).
  • Gaskin v. Commonwealth of Pennsylvania

    Pennsylvania had very low rates of inclusion and this case fought to address that. They had hoped to increase the amount of students with disabilities being educated with their peers in the regular education settings. This cause brought to light how the state was failing to meet IDEA requirements and created reforms for the state to ensure that the IDEA requirements were being met and students were being educated in the least restricted environment (Kids Together Inc, N.D.).
  • The IDEA Amendments of 1997

    The IDEA Amendments of 1997 made improvements to IDEA, emphasizing the importance that students with disabilities receive a quality public education and it did so by requiring demonstrable improvements in their academic achievements (Yell, 2019).
  • Cedar Rapids Community School District v. Garret F.

    Cedar Rapids Community School District v. Garret F. ruled that it was the school district's responsibility to provide any and all necessary health services to students with disabilities, no matter how complex or costly these services may be, as long as they did not require a physician (Yell, 2019).
  • No Child Left Behind Act

    No Child Left Behind Act
    The No Child Left Behind Act was signed by President George W. Bush in 2001. The focus of the Act was to address students with low academic achievement and greatly expand the federal government's role in public education. It ultimately held districts and schools accountable for their student's performance based on their achievement and growth in reading and mathematics scores (Yell, 2019).
  • IDEA Amendment

    The IDEA Amendment of 2004 had significant changes in special education. These changes included requiring teachers to be qualified in special education, changes in IEPs, and addressed the discipline and identification of students with disabilities (Yell, 2019).
  • The Every Student Succeeds Act

    The Every Student Succeeds Act
    The Every Student Succeeds Act eliminated many of the controversial NCLB requirements. It also shifted many roles of the U.S. Department of Education to the states. In addition, it allowed school districts to provide alternate achievement tests to 1% of its student population (Yell,2019).
  • Endrew F. v. The Douglas County School District

    In 2017, the U.S. Supreme Court ruled in favor of schools having higher stands of education for children with disabilities increasing educational expectations (McKenna, 2017)