A Modern Analysis with Technology Considerations

D.R. v. Redondo Beach Unified School District (9th Cir. 2022)

Key Facts:

• Student with autism required extensive behavioral support
• District proposed moving student from general education to special day class
• Parents argued for maintaining placement with additional supports

Court's Ruling:

• Upheld district's decision for more restrictive environment
• However, established important guidelines for LRE analysis:
  • Districts must provide clear evidence that student cannot be educated in general education with appropriate supports
  • Must demonstrate meaningful consideration of supplementary aids and services
  • Need to show that behavioral challenges significantly impair educational experience of other students

Significance:

• Reinforces that LRE decisions must be individualized
• Places burden on district to prove need for more restrictive environment
• Emphasizes importance of documenting attempted interventions

Sacramento City Unified School District v. Rachel H. (9th Cir. 1994)

Key Facts:

• Student with intellectual disability sought full inclusion in regular classroom
• District proposed part-time special education placement
• Parents advocated for full inclusion with supports

Court's Analysis Framework:

Established four-factor balancing test for LRE decisions: