Firm News & Updates

Private Special Education Programs and Therapeutic Schools in Connecticut for Children with Special Needs

Forte Law Group, a special education and child advocacy law firm, has compiled an extensive list of private special education programs and therapeutic schools that are available to children with special needs in Connecticut. The list of schools is provided in alphabetical order, as well as by county, with a hyperlink to the website of each school.

Alphabetically by school

Adelbrook Behavioral and Developmental Services – Cromwell and Manchester, CT
www.adelbrook.org

American School for the Deaf – West Hartford, CT
www.asd-1817.org

Arch Bridge School at Wellspring – Bethlehem, CT
www.wellspring.org

Ben Bronz Academy – West Hartford, CT
www.benbronzacademy.org

Benhaven – North Haven, CT
www.behaven.org

Boys & Girls Village – Milford, CT
www.bgvillage.org

Carmel Academy – Greenwich, CT
www.carmelacademy.com

CCMC School – New Britain, CT
www.ccmcschool.org

Cedarhurst School – Hamden, CT
www.cedarhurst.yale.edu

Chapel Haven – New Haven, CT
www.chapelhaven.org

Community Child Guidance Clinic – Manchester, CT
www.ccgcinc.org

Connecticut College Children’s Program – New London, CT
www.conncoll.edu

Connecticut Junior Republic – Litchfield, CT
www.ctjuniorrepublic.org

Eagle Hill School – Greenwich, CT
www.eaglehillschoo.org

Eagle House Education Program – Hartford, CT
www.thevillage.org

Elizabeth Ives School for Special Education – North Haven, CT
www.capsef.org/Members/memberview.asp?programid=27

Foundation School – Milford and Orange, CT
www.foundationschool.org

Franklin Academy – East Haddam, CT
www.fa-ct.org

Futures School – West Hartford, CT
www.futures-ct.org

Gengras Center School – West Hartford, CT
www.gengrascenter.org

Giant Steps School Connecticut School – Southport, CT
www.giantstepsct.org

The Glenholme School – Washington, CT
www.theglenhomeschool.org

Grove School – Madison, CT
www.groveschool.org

High Road Academy of Wallingford – Wallingford, CT
www.catapultlearning.com

High Road School of Hartford High – Hartford, CT
www.catapultlearning.com

High Road School of Hartford Primary – Hartford, CT
www.catapultlearning.com

High Road School of New London – New London, CT
www.catapultlearning.com

High Road School of Norwalk – Norwalk, CT
www.catapultlearning.com

High Road School of Wallingford – Wallingford, CT
www.catapultlearning.com

High Road Academy of Waterbury – Waterbury, CT
www.catapultlearning.com

Hope Academy – Orange, CT
www.hopeacademyct.com

IPP (The Institute of Professional Practice) – Stratford, CT
www.ippi.org

Intensive Education Academy – West Hartford, CT
www.ie-academy.org

The Learning Clinic – Brooklyn, CT –
www.thelearningclinic.org

The Light House – Groton, CT
www.lhcampus.com

LINKS Academy – New Canaan, Stamford and Riverside, CT –
www.linksacademy.org

Lorraine D. Foster Day School – Hamden, CT
www.ldfds.com

Manchester Memorial Hospital Clinical Day School – Manchester, CT
www.echn.org/clinical-day-school

Meliora Academy – Meriden, CT
www.melioraacademy.net

Milestones Behavioral Services (formerly Connecticut Center for Child Development) – Milford and Orange, CT
www.mbs-inc.org

Natchaug Hospital Inpatient School – Mansfield, CT
www.natchaug.org/programs-services/schools/departments-services/the-inpatient-school-program

Natchaug Hospital Journey School – Mansfield, CT
www.natchaug.org/programs-services/schools/departments-services/the-journey-house-school

Natchaug Hospital School – Mansfield, Danielson, Enfield, Norwich, Old Saybrook, and Willimantic, CT
www.natchaug.org/programs-services/schools

Northwest Village School / Northwest Village School – Plainville, CT www.wheelerclinic.org/your-student/northwest-village-school

Oak Hill School – Hartford, CT
www.oakhillct.org

Options Educational Services – Hartford, CT
www.capsef.org/Members/memberview.asp?programid=90

Oxford Academy – Westbrook, CT
www.oxfordacademy.net

PACES (Positive Attitude Concerning Education and Socialization) – West Hartford, CT
www.asd-1817.org/asd/paces

Pinnacle School – Stamford, CT
www.pinnacle-ct.org

Raymond Hill School – New Britain, CT
www.klingberg.org/programs-services/raymond-hill-school

Rushford Academy – Durham, CT
www.rushford.org/programs-services/rushford-academy

Saint Catherine Academy – Fairfield, CT
www.stcatherineacademy.org

SARAH, Inc. (KidSteps Family and Children’s Center) – Guilford, CT
www.sarah-inc.org

Solterra Academy – New Britain, CT
www.solterraacademy.com

The Southport School – Southport, CT
www.southportschool.org

The Speech Academy – Easton, CT
www.thespeechacademy.org

Spire School – Stamford, CT
www.spireschool.org

St. Vincent’s Special Needs School Program – Trumbull, CT
www.stvincentsspecialneeds.org

The Susan Wayne Center of Excellence – Thompson, CT
www.jri.org/services/ct/educational-and-residential/susan-wayne-day-school

The Transition Academy of Mount Saint John – Deep River, CT
www.mtstjohn.org

Touchstone School – Litchfield, CT
www.nafict.org/services/educational-services/touchstone-school

Villa Maria Education Center – Stamford, CT
www.villamariaedu.org

Waterford Country School – Waterford, CT
www.waterfordcountryschool.org

The Webb School – Hartford, CT
www.instituteofliving.org/programs-services/the-webb-school-programs

Westport Day School – Wilton, CT
www.westportdayschool.org

Whitney Hall School – Hamden, CT
www.childrenscenterhamden.org/programs/whitney-hall-school-residential

Winston Preparatory School – Norwalk, CT
www.winstonprep.edu

Woodhouse Academy – Milford, CT
www.woodhouseacademy.com

Wooster School, Prospect Program – Danbury, CT
www.woosterschool.org/page.cfm?p=559

Yale Child Study Center School – New Haven, CT
www.medicine.yale.edu/childstudy

 

Alphabetically by County

 

Fairfield County

Carmel Academy – Greenwich, CT www.carmelacademy.com

Eagle Hill School – Greenwich, CT www.eaglehillschoo.org

Giant Steps School Connecticut School – Southport, CT www.giantstepsct.org

High Road School of Norwalk – Norwalk, CT www.catapultlearning.com

LINKS Academy – New Canaan, Stamford and Riverside, CT – www.linksacademy.org

Pinnacle School – Stamford, CT www.pinnacle-ct.org

Saint Catherine Academy – Fairfield, CT www.stcatherineacademy.org

The Southport School – Southport, CT www.southportschool.org

The Speech Academy – Easton, CT www.thespeechacademy.org

Spire School – Stamford, CT www.spireschool.org

St. Vincent’s Special Needs School Program – Trumbull, CT www.stvincentsspecialneeds.org

Villa Maria Education Center – Stamford, CT www.villamariaedu.org

Westport Day School – Wilton, CT www.westportdayschool.org

Winston Preparatory School – Norwalk, CT www.winstonprep.edu

 

Hartford County

Adelbrook Behavioral and Developmental Services – Cromwell and Manchester, CT www.adelbrook.org

American School for the Deaf – West Hartford, CT www.asd-1817.org

Ben Bronz Academy – West Hartford, CT www.benbronzacademy.org

CCMC School – New Britain, CT www.ccmcschool.org

Community Child Guidance Clinic – Manchester, CT www.ccgcinc.org

Eagle House Education Program – Hartford, CT www.thevillage.org

Futures School – West Hartford, CT www.futures-ct.org

Gengras Center School – West Hartford, CT www.gengrascenter.org

High Road School of Hartford High – Hartford, CT www.catapultlearning.com

High Road School of Hartford Primary – Hartford, CT www.catapultlearning.com

Intensive Education Academy – West Hartford, CT www.ie-academy.org

Manchester Memorial Hospital Clinical Day School – Manchester, CT www.echn.org/clinical-day-school

Natchaug Hospital School – Mansfield, Danielson, Enfield, Norwich, Old Saybrook, and Willimantic, CT www.natchaug.org/programs-services/schools

Northwest Village School / Northwest Village School – Plainville, CT www.wheelerclinic.org/your-student/northwest-village-school

Oak Hill School – Hartford, CT www.oakhillct.org

Options Educational Services – Hartford, CT www.capsef.org/Members/memberview.asp?programid=90

PACES (Positive Attitude Concerning Education and Socialization) – West Hartford, CT www.asd-1817.org/asd/paces

Raymond Hill School – New Britain, CT www.klingberg.org/programs-services/raymond-hill-school

Solterra Academy – New Britain, CT
www.solterraacademy.com

The Webb School – Hartford, CT www.instituteofliving.org/programs-services/the-webb-school-programs

 

Litchfield County

Arch Bridge School at Wellspring – Bethlehem, CT www.wellspring.org

Connecticut Junior Republic – Litchfield, CT www.ctjuniorrepublic.org

The Glenholme School – Washington, CT www.theglenhomeschool.org

Touchstone School – Litchfield, CT www.nafict.org/services/educational-services/touchstone-school

Wooster School, Prospect Program – Danbury, CT www.woosterschool.org/page.cfm?p=559

 

Middlesex County

Refer to schools within the counties of Hartford, New Haven, and New London.

 

New Haven County

Benhaven – North Haven, CT www.behaven.org

Boys & Girls Village – Milford, CT www.bgvillage.org

Cedarhurst School – Hamden, CT www.cedarhurst.yale.edu

Chapel Haven – New Haven, CT www.chapelhaven.org

Elizabeth Ives School for Special Education – North Haven, CT www.capsef.org/Members/memberview.asp?programid=27

Foundation School – Milford and Orange, CT www.foundationschool.org

High Road Academy of Wallingford – Wallingford, CT www.catapultlearning.com

High Road School of Wallingford – Wallingford, CT www.catapultlearning.com

High Road Academy of Waterbury – Waterbury, CT www.catapultlearning.com

Hope Academy – Orange, CT www.hopeacademyct.com

IPP (The Institute of Professional Practice) – Stratford, CT www.ippi.org

Lorraine D. Foster Day School – Hamden, CT www.ldfds.com

Meliora Academy – Meriden, CT www.melioraacademy.net

Milestones Behavioral Services (formerly Connecticut Center for Child Development) – Milford and Orange, CT www.mbs-inc.org

Rushford Academy – Durham, CT www.rushford.org/programs-services/rushford-academy

Whitney Hall School – Hamden, CT www.childrenscenterhamden.org/programs/whitney-hall-school-residential

Woodhouse Academy – Milford, CT www.woodhouseacademy.com

Yale Child Study Center School – New Haven, CT www.medicine.yale.edu/childstudy

 

New London County

Connecticut College Children’s Program – New London, CT www.conncoll.edu

Franklin Academy – East Haddam, CT www.fa-ct.org

Grove School – Madison, CT www.groveschool.org

High Road School of New London – New London, CT www.catapultlearning.com

The Light House – Groton, CT www.lhcampus.com

Natchaug Hospital School –Norwich and Old Saybrook, CT www.natchaug.org/programs-services/schools

Oxford Academy – Westbrook, CT www.oxfordacademy.net

SARAH, Inc. (KidSteps Family and Children’s Center) – Guilford, CT www.sarah-inc.org

The Transition Academy of Mount Saint John – Deep River, CT www.mtstjohn.org

Waterford Country School – Waterford, CT www.waterfordcountryschool.org

 

Tolland County

Refer to the counties of Windham, New London, Middlesex and Hartford.

 

Windham County

The Learning Clinic – Brooklyn, CT – www.thelearningclinic.org

Natchaug Hospital Inpatient School – Mansfield, CT www.natchaug.org/programs-services/schools/departments-services/the-inpatient-school-program

Natchaug Hospital Journey School – Mansfield, CT www.natchaug.org/programs-services/schools/departments-services/the-journey-house-school

Natchaug Hospital School – Mansfield, Danielson, and Willimantic, CT www.natchaug.org/programs-services/schools

The Susan Wayne Center of Excellence – Thompson, CT www.jri.org/services/ct/educational-and-residential/susan-wayne-day-school

 

Disclaimer: This list is intended for informational and educational purposes only. The reader should contact the school(s) for further information.

Stepping Stones Hosts Program with Guest Speaker Attorney Jeffrey Forte – Norwalk, CT

Parents will learn about the Individuals with Disabilities Education Act (IDEA), Free Appropriate Public Education (FAPE), Individualized Education Program (IEP), Family Educational Rights Privacy Act (FERPA), Independent Educational Evaluation (IEE), Related Services, and IEP vs 504 Plan. This program will be presented by guest speaker Jeffrey Forte on February 19, 2018, 6:00pm-7:30pm Stepping Stones Museum for Children at 303 West Avenue in Norwalk, CT.

Meet Attorney Jeff Forte – Special Education Law Q&A in Darien, CT

Jeffrey Forte will present a free talk on Special Education Law at the Darien Library on Thursday, February 15 at the Darien Library entitled “Empowering Parents to Advocate for Their Child’s Rights.”

Topics will include:

  • Ambitiously Appropriate IEP Goals & Objectives
  • What Happens When Your Child Isn’t Progressing at School
  • What Happens When the School District Denies or Takes Away Services
  • Addressing IEP Verses 504 Plans, What’s the Difference
  • A question and answer session will follow the presentation for further discussion.

Jeffrey Forte is a founding member of Forte Law Group, LLC and is one of the few attorneys in Connecticut that has obtained a Certificate in Special Education Advocacy from the Institute of Special Education Advocacy (ISEA) at William & Mary Law School in Williamsburg, Virginia. For more than 16 years, Jeff has devoted his entire legal career to serving the Connecticut community, advocating and negotiating on behalf of his clients.

Q&A Legal Workshop with Attorney Jeff Forte – West Hartford, CT

Learn, listen and network with fellow parents of children with special needs on January 25, 2018 at 6:30pm the West Hartford Public Library as Special Education Lawyer & Certified Child Advocate, Jeffrey Forte, J.D., presents on:

-Special education law and how it relates to addressing challenging behaviors at school.
-Importance of evaluating a child’s challenging behavior by conducting an FBA.
-Explain the procedures for conducting an FBA.
-Using information from the FBA to develop a comprehensive BSP.
-Requesting an IEE when the parents are not in agreement with the evaluation.
-Ten quick tips to prepare for a PPT to review an FBA.

Procedural Safeguards, FAPE, IEEs and Related Services Presentation in Fairfield, CT

Hosted by the Fairfield Public Library located at 1080 Old Post Road in Fairfield, CT on January 11, 2018, 6:30pm to 7:30p, certified child advocate and special education attorney Jeffrey Forte will present a free workshop for parents of children with special needs. The program will include a substantive presentation on a child’s right to a free appropriate public education under the Individuals with Disabilities Education Act. To register, sign up at: https://tinyurl.com/yapk8zmw

Special Education Rights for Children with Autism Presented by Attorney Jeffrey Forte – Greenwich, CT

Free program for parents of children with autism held at the Greenwich Library located at 101 West Putman Avenue in Greenwich, CT on January 18, 2018 from 5:30-7:30pm. Presented by special education attorney and certified child advocated Jeffrey Forte, the program will cover:

-Critical Discussion about the Individuals with Disabilities Education Act.
-Evaluations, Reevaluations and Independent Educational Evaluations.
-Planning and Placement Team Meeting Strategies.
-Ambitiously appropriate IEP Goals & Objectives.

5 Quick Tips for Promoting Effective Communication with Your Child’s IEP team

Communication with your child’s IEP team should NEVER be limited to just the annual review.  Be proactive and establish effective methods of communicating with your child’s IEP team on a regular basis from the beginning of each school year or at your child’s annual review.  As a parent, you are a member of the school team and as such should be active and thoroughly informed about your child’s education on an ongoing basis.  Here are a few tips on how to promote effective communication with your child’s IEP team:

1. Communication Logs are a Must.

Establish a daily or weekly home and school communication log (via electronic student portal or paper).  The communication log is a method for school team members to broadly share information about the learning activities your child participated in across the school day (including activities delivered by service providers).  As a parent, you should participate in the development of the communication log so that it captures the information that is important to you.

2. Parent Meetings are Essential.

Set up regular parent meetings (monthly or quarterly depending child’s level of need) with your IEP team.  Parent meetings can serve multiple functions but generally speaking can be a time for team members to share information about your child’s progress, discuss ways to promote the generalization of acquired skills in the home/community setting, share and review data, troubleshoot, and discuss changes in the home setting, to name a few.

3. Be Prepared.

Effectively communicating with your IEP team also means that you should be prepared to participate in the discussion about your child’s progress and/or evaluations.  This means you will need to formally request (in writing) that you receive any progress reports, evaluations, data, or related documents that will be reviewed at your child’s IEP meeting ahead of time.  This is a critical request and one that should be done before each and every IEP meeting.  For more information on how to prepare for an IEP meeting go to http://www.fortelawgroup.com/ten-quick-tips-advice-prepare-iep-meeting/.

4. Formally Request Methods of Communication on IEP.

Be sure to always formally request any methods of communication at an IEP meeting to be included on the IEP. Remember if it is not included on the IEP then it is likely not to happen.  Parents often make the mistake of not formally making these requests and leave the IEP meeting without a clear solution to the communication issue.  It is important to clearly share the concern with the IEP team with regards to communication but also propose a solution by making a formal request to include the solution (e.g., communication log, parent meeting, data review meeting, etc.) on the IEP.

5. Never Hesitate.

If you have a concern, question, or simply something to share with your school team about your child do not hesitate to contact them.  It is critical to your child’s education that you establish an open line of communication.  In my experience, some families have expressed frustration with establishing effective methods of communication with their IEP team.  If this is your case, then do not hesitate to contact an advocate or education law attorney to discuss how you can move forward with promoting effective communication methods with your child’s IEP team.

 

Forte Law Group is one of only a very few law firms within the state of Connecticut that is dedicated to exclusively representing families and children with special needs. Whether you need an attorney to attend your child’s PPT meeting, represent you during mediation, or need an attorney to bring a due process action against the school district, Forte Law Group stands apart because we provide our clients with an unprecedented amount of legal and educational guidance, resources and support throughout the entire scope of your legal representation.

Attorney Jeffrey L. Forte is both an advocate and lawyer who is certified in special education advocacy. For more information visit ForteLawGroup.com, follow us on Facebook at or call us at (203) 257-7999.

 

Special Education Law & Music Therapy as a Related Service – Fairfield County, CT

Hosted by Connecticut Music Therapy Service, certified child advocate and special education lawyer Jeffrey Forte will present with Emily Bevelaqua, MMT, MT and Kelsy Gati, MT-BC on how to advocate for music therapy as a related service in your child’s IEP. The program will be held at January 9, 2018 6:30pm-7:30pm located at 2505 Black Rock Turnpike in Fairfield, CT and will include a discussion on:

-Overview of the IDEA & FAPE.
-Related services under the IDEA.
-What is music therapy?
-Securing music therapy as a related service on your child’s IEP.
-What is SEMTAP?
-Outcomes of music therapy as a related service.

Independent Educational Evaluations (IEEs), Handling PPTs and FERPA School Records Requests – Orange, CT

The Rotary Club of Orange, CT is hosting a meeting for all its members to learn about special education law and the rights of parents of child with special needs. Special education lawyer and certified child advocated Jeffrey Forte is the invited guest speaker. The event will be held on January 4, 2018 12:15pm-1:15pm located at Rotary Club of Orange, CT.

What’s the Law on Recording a PPT / IEP Meeting in Connecticut?

Parents often ask me whether they are allowed to record their child’s Individualized Education Program (IEP) team meeting. Here in Connecticut, an IEP meeting is referred to as the Planning and Placement Team meeting (PPT) in which to discuss the child’s IEP. To fully answer this question, we will first examine what the law in the state of Connecticut says about whether or not you can record a PPT / IEP meeting. After that, we will briefly discuss strategy and recommendations on recording an IEP meeting.

Connecticut Law

In Connecticut, there are two court decisions that rule parents have the right to record a PPT / IEP meeting. The court decisions are E.H. v. Tirozzi, 735 F. Supp. 53 (D. Conn. 1990) and V.W. v. Favolise, 131 F.R.D. 654 (D. Conn. 1990). Both decisions are referenced in a June 4, 2003 letter issued by the U.S. Department of Education, Office of Special Education Programs (OSEP), which states their position on audio recording an IEP meeting.

In the first case, the court held that a parent, whose native language is other than English and has difficulty understanding English, has the right to tape record her child’s IEP meeting. In the second case, the court held that based on the parent’s own disability, the parent has the right to record the IEP meeting. In addition, in the second case, one of the two parents had a scheduling conflict and was not available to make the PPT / IEP meeting and requested a verbatim record to better understand what transpired.

It is important to highlight the court recognized the mother’s right to record her child’s PPT/IEP meeting in its entirety, including “over the objection of any member” of the planning and placement school team. E.H v. Tirozzi, 735 F. Supp at 57 (emphasis added). The court provided that under the Individuals with Disabilities Education Act (IDEA), the Act is designed to help implement the individualized education plan (IEP) for the educational benefit of the child with a disability and the child’s parents. Under the IDEA, the parents are both an essential and equal member of the planning and placement team to help develop their child’s IEP. Thus, if the parents have difficulty understanding what is taking place at their child’s IEP meeting, they are effectively being deprived of one of the procedural safeguards under the IDEA, which is to participate and effectively evaluate their child’s IEP with the planning and placement team. A recording of the meeting allows the parents to go home and review what was said at the meeting again and again so that they may more fully assist in the development of their child’s IEP. Id. The court further held that the refusal from members of the school team to be recorded does not outweigh the legitimate and substantial interests under the IDEA of ensuring the parents right to meaningful participation in the PPT meeting. Id. at 58.

Strategy and Recommendations

As a practical matter as well as professional courtesy, if you do plan on recording your child’s PPT / IEP meeting, I strongly recommend you inform the school team, in writing, of your intention to do so in advance of the meeting. First, in the spirit of being collaborative and supportive with your child’s school team, you do not want to be perceived as being sneaky or secretive about recording the meeting. This is especially true if the matter goes to due process before an impartial hearing officer. Second, by providing the school team with advance notice, time will neither be delayed nor wasted on the day of the PPT / IEP meeting with the school team trying to find or locate an official school recording device to preserve their record. Lastly, even if your local education agency or school district has a policy in place (most do not) that limits or prohibits a parent’s right to record the PPT / IEP proceedings, there must be exceptions to that policy to ensure that the parent is able to understand the proceedings, which include a parent’s right to understand and participate at the PPT / IEP meeting, parent availability to attend, and other intellectual or physical factors that may interfere with a parent’s right to fully and equally understand and participate in the development of their child’s IEP.

For more information about recording a PPT / IEP meeting, call 203-257-7999 or email jforte@fortelawgroup.com to schedule an appointment with special education lawyer and certified child advocate, attorney Jeffrey Forte of Forte Law Group LLC.

Comprehensive Dictionary of Special Education Acronyms

© Forte Law Group, November 2017
By Jeffrey L. Forte, Connecticut Special Education Lawyer and Certified Child Advocate

A
AAC        Augmentative/Alternative Communication
ABA        Applied Behavior Analysis
ABC        Antecedent, Behavior, Consequence
ABS         Adaptive Behavior Scale
ADA        Americans with Disabilities Act
ADD       Attention Deficit Disorder
ADHD    Attention Deficit Hyperactivity Disorder
ADLs       Activities of Daily Living
ADR        Alternative Dispute Resolution
AE           Age Equivalent
AEM       Accessible Educational Materials
AIM        Accessible Instructional Materials
ALD        Assistive Listening Device
AP           Advanced Placement
APE         Adapted Physical Education
APR        Annual Performance Report
APS         Approve Private School
AS           Asperger’s Syndrome or Autism Spectrum
ASD        Autism Spectrum Disorder
ASL         American Sign Language
AT           Assistive Technology
AYP         Adequate Yearly Progress

 

B
BASC      Behavior Rating Scale for Children (test)
BCaBA Board Certified Assistant Behavior Analyst
BCBA      Board Certified Behavior Analyst
BCBA-D Board Certified Behavior Analyst-Doctoral
BD          Behavior Disorder
BEC         Basic Education Calendar
BESB      Connecticut Bureau of Education and Services for the Blind
BIP          Behavioral Intervention Plan
BOE        Board of Education
BYOD     Bring Your Own Device
 

C
CA           Chronological Age
CAP         Corrective Action Plan
CAPD      Central Auditory Processing Disorder
CAPT      Connecticut Academic Performance Test
CBA        Curriculum-Based Assessment
CBA        Child Development Association
CC           Closed Captioning
CCSS       Common Core State Standards
CDC        Center for Disease Control and Prevention
CDT        Classroom Diagnostic Tools
CF            Cystic Fibrosis
CFR         Code of Federal Regulations
CGA        Connecticut General Assembly
CGS         Connecticut General Statutes
CMT       Connecticut Mastery Test
COP        Community of Practice
COPAA   Council of Parent Attorneys and Advocates
CP           Cerebral Palsy
CPAC      Connecticut Parent Advocacy Center
CSDE      Connecticut State Department of Education
CST         Child Study Team
CTAA      Connecticut Alternative Assessment
CTAPP    Connecticut Tech Act Project
CTEDTECH  Connecticut Commission for Educational Technology

 

D
DB          Deaf/Blind
DCF         Department of Children and Families
DD          Developmental Disability
DDS        Department of Developmental Services
DIS          Designated Instruction and Services
DMHAS Department of Mental Health & Addiction Services
DOE        Department of Education
DORS     Connecticut Department of Rehabilitation Services
DS           Down Syndrome
DSM-V   Diagnostic and Statistical Manual of Mental Disorders
DSS         Department of Social Services

 

E
EBR        Educational Benefit Review
ECE         Early Childhood Education
ECSE       Early Childhood Special Education
ED           Emotional Disability
ED           U.S. Department of Education
EDGAR Education Department General Administrative Regulations
EHA        Education of the Handicapped Act (now IDEA)
EHDI      Early Hearing Detection and Intervention
EI            Early Intervention
EIS          Early Intervention Services
ELL          English Language Learner (previously ESL)
ER           Evaluation Report
ESD         Extended School Day
ESQ         Esquire/Attorney/Lawyer
ESSA       Every Student Succeeds Act
ESY         Extended School Year
ETV         Educational and Training Voucher
EVT         Expressive Vocabulary Test

 

F
FAPE       Free Appropriate Public Education
FAS         Fetal Alcohol Syndrome
FC            Facilitated Communication
FERPA    Family Educational Rights and Privacy Act
FBA         Functional Behavioral Assessment
FLG         Forte Law Group, a Special Education & Child Advocacy Law Firm (that’s us!)
FOIA       Freedom of Information Act

 

G
GAD       Guardian Ad Litem
GE           General Education or Grade Equivalent
GED        General Equivalency Diploma
GLE         Grade Level Expectations
GORT-4  Gray Oral Reading Test, 4th Edition
GT           Gifted and Talented

 

H
HI            Hearing Impaired
HO          Hearing Officer
HOH       Hard of Hearing
HQT        Highly Qualified Teacher

 

I
IA            Instructional Assistant
ID            Intellectual Disability (to replace MR)
IDEA       Individuals with Disabilities Education Act
IDEIA     Individuals with Disabilities Education Improvement Act (2004)
IEE          Independent Educational Evaluation
IEP          Individualized Education Program
IFC          Intensive Foster Care
IFSP        Individualized Family Service Plan
IHE         Institute of Higher Education
IQ            Intelligence Quotient
ITP          Individual Transition Plan

 

J
JD            Judicial District or Juris Doctorate
JF             Jeffrey Forte, Special Education Lawyer & Certified Child Advocate (that’s me!)

 

K
K              Kindergarten
 

L
LD           Learning Disability
LEA         Local Education Agency
LEP         Limited English Proficient
LGBT      Lesbian, Gay, Bisexual and Transgender
LRE         Least Restrictive Environment

 

M
MA         Medical Assistance or Mental Age
MD         Multiple Disabilities or Muscular Dystrophy
MDR      Manifestation Determination Review
MDT       Multi-Disciplinary Team
MID        Mild Intellectual Disability
MH         Multiple Handicapped
MOU      Memorandum of Understanding
MR         Mental Retardation (replaced by ID)
MS          Multiple Sclerosis
 

N
NCLB      No Child Left Behind Act (Elementary and Secondary Education Act)
NGSS      Next Generation Science Standards Test
NIMAS   National Institute of Mental Health
NPA        Nonpublic Agency
NPS         Nonpublic School (private)

 

O
O&M      Orientation and Mobility
OAH       Office of Administrative Hearings
OEC        Connecticut Office of Early Childhood
OCA        Office of the Child Advocate
OCD        Obsessive-Compulsive Disorder
OCR        Office of Civil Rights
OCS         On-Campus Suspension
ODD       Oppositional Defiant Disorder
OHI         Other Health Impaired
OI            Orthopedically Impaired
OT           Occupational Therapy

 

P
P&A        Protection & Advocacy
PALS       Peer-Assisted Learning System
Para       Paraprofessional
PASS       Plan for Achieving Self-Support
PBS         Positive Behavioral Supports
PBIS        Positive Behavior Interventions and Support
PBSP       Positive Behavior Support Plan
PCA         Personal Care Assistant
PD           Physical Disability
PDD        Pervasive Developmental Disorder
PEAC      Performance Evaluation Advisory Council
PEI          Spanish acronym for IEP (Plan Educativo Individualizado)
PL            Public Law
PLP         Present Level of Performance
PLEP       Present Level of Education Performance
POA        Power of Attorney
PP           Paraprofessional
PPT         Planning Placement Team
PQA        Program Quality Assistance
Pre-K      Pre-Kindergarten
PS            Preschool or Private School
PSN         Procedural Safeguards Notice
PT           Physical Therapy
PTA         Parent-Teacher Association
PTI          Parent Training and Information Center
PTSD      Post-Traumatic Stress Disorder
PWN       Prior Written Notice

 

Q

 

R
RAD        Reactive Attachment Disorder
RBT        Registered Behavior Technician
RFP         Request for Proposals
RR           Re-evaluation Report
RS           Related Services
RSP         Resource Specialist Program
RTI          Response to Intervention

 

S
SA           Self-Assessment
SaS          Supplementary Aides and Services
SAT         Scholastic Assessment/Aptitude Test
SB           Spina Bifida
SBAC      Smarter Balanced Assessment Consortium
SBBH      School Based Behavioral Health
SCTG      School Climate Transformation Grant
SE            Special Education
SEA         State Education Agency
Sec 504  Section 504 of the Rehabilitation Act
SERC       State Education Resource Center of Connecticut
SCC         Self-contained Classroom
SDC         Special Day Class
SDE         State Department of Education
SDI          Specifically Designed Instruction
SED         Serious Emotional Disability
SEPTA    Special Education Parent Teacher Association
SERC       State Education Resource Center
SESP       Special Education Surrogate Parent
SH           Severely Handicapped
SI             Sensory Integration
SIB          Self-Injurious Behavior
SLD         Specific Learning Disability
SLI           Speech/Language Impaired
SLP          Speech Language Pathologist
SPED      Special Education
SPDG      State Personnel Development Grant
SPOA      Specific Power of Attorney
SRBI       Scientific Research-Based Interventions
SSDI        Social Security Disability Income
SS            Scaled Score
SSI           Supplemental Security Income
SSIP        State Systemic Improvement Plan
SST          Student Study Team
STEM     Science, Technology, Engineering and Math
STOs       Short-Term Objectives
SY            School Year

 

T
TAG        Talented and Gifted
TDD        Telecommunication Devices for the Deaf
TBI          Traumatic Brain Injury
TP           Transition Planning
TS            Tourette Syndrome
TScore
TSS          Therapeutic Staff Support
T-TA       Training and Technical Assistance
TTY         Teletypewriter (phone system for the Deaf)

 

U
UDL        Universal Design for Learning
U.S.C.     United States Code

 

V
VI            Visually Impaired/Visual Impairment
Voc Ed Vocational Education
VR           Visiting Resource or Vocational Education

 

W
WAIS      Weschler Adult Intelligence Scale
WIAT      Weschler Individual Achievement Test
WISC-IV  Weschler Intelligence Scale for Childre, 4th Edition
WPN       Written Prior Notice

 

X
X-Axis     In Mathematics, the horizontal axis

 

Y
Y-Axis     in Mathematics, the vertical axis

 

Z
Z-Score

© Forte Law Group, November 2017
For more information, contact Forte Law Group at (203) 257-7999.

What Does Licensure for Behavior Analysts Mean for Your Child with an IEP?

It has been long overdue! Governor Malloy has signed a budget bill that includes licensure for behavior analysts in the state of Connecticut. What does this mean? How does this impact your child’s services or IEP?

A Board Certified Behavior Analyst (BCBA) is a graduate level independent practitioner who has met the requirements established by the Behavior Analyst Certification Board (BACB) to become certified in providing assessment and treatment based on the principles of applied behavior analysis. Behavior Analysts are able to supervise the work of individuals implementing behavior analytic services such as a Board Certified Assistant Behavior Analyst (BCaBA), Registered Behavior Technician (RBT), special education teachers, paraprofessionals or any other individual implementing behavioral analytic strategies.

Licensure for Behavior Analysts will be put into effect July 2018. What this means is that the prior to licensure the field and practice was not regulated in the state of Connecticut. Since the establishment of the BCBA credential in 1998, twenty-nine states have enacted licensure for behavior analysts in order to increase consumer protection for the vulnerable population of individuals that Behavior Analysts serve by putting forth regulations at the state level. More specifically, licensure offers protection to students receiving Applied Behavior Analysis (ABA) services across all settings including home, school, and community. ABA is an established evidence-based practice that many individuals benefit from particularly those diagnosed with autism spectrum disorders. Many of these individuals receive ABA services through their IEPs and now the state can assure that the individuals providing these services are not only credentialed but also licensed by the state of Connecticut.

For more information related to how licensure for behavior analysts will impact your child’s IEP please do not hesitate to contact the Forte Law Group, LLC at (203) 257-7999.

Functional Behavioral Assessments and Behavior Intervention Plans – Hosted at The Waverly Group in Greenwich, CT.

The Waverly Group is a free parent workshop for parents of children with special needs on November 3, 2017 from 10am to 11am at 1445 East Putnam Avenue in Old Greenwich, CT. Special education attorney and certified child advocate Jeffrey Forte of Forte Law Group will be the guest speak to present on FBA, BIPs and special education law.

ASRC – Autism Services & Resources Connecticut to include Special Education Attorney Jeffrey Forte at the 2017 Annual Resource Fair

Special education attorney Jeffrey Forte of Forte Law Group LLC will be a legal exhibitor the 2017 Annual ASRC Autism Resource Fair to answer any and all special education law questions to parents of children on the autism spectrum on a complimentary basis. The event is free to attendees based on the support of participating service providers, like Forte Law Group LLC, supporting this event. Be sure to stop by our table to meet Attorney Jeffrey Forte and to learn more about Forte Law Group. For more information about the fair, visit http://www.ct-asrc.org/ The event will be held on November 4, 2017, 9:00am to 3:00pm Oakdale Theater Complex located at 95 South Turnpike Road in Wallingford, CT.

Attorney Jeffrey Forte to Participate at ASRC Annual Fair

Attorney Jeffrey Forte of Forte Law Group LLC will be a legal exhibitor the 2017 Annual ASRC Autism Resource Fair. Autism Services & Resources Connecticut (ASRC) will be hosting the annual fair on November 4, 2017 from 9:00am to 3:00pm at the Oakdale Theater Complex located at 95 South Turnpike Road in Wallingford, Connecticut.

This event historically draws hundreds of attendees seeking more information about autism resources in Connecticut. The event is free to attendees based on the support of participating service providers, like Forte Law Group LLC, supporting this event. Be sure to stop by our table to meet Attorney Jeffrey Forte and to learn more about Forte Law Group. For more information about the fair, visit http://www.ct-asrc.org/

Attorney Jeffrey Forte has been invited to co-present ACES BAES

Attorney Jeffrey Forte has been invited to co-present at the fourth annual ACES Behavior Analysis in Education Series (BAES). ACES Behavior Analysis in Education Series provides continuing education opportunities to behavior analysts, teachers, therapists, parents and administrators and will address important areas in the application of behavior analysis in education. Mr. Forte will be co-presenting with Professor Michael F. Dorsey, Ph.D., LABA, BCBA-D, of Endicott College.

The title of the presentation is The Behavior Analyst and Independent Educational Evaluations. To register, click here.

History of Special Education: Important Landmark Cases

FORTE LAW GROUP PRACTICE PAPER:

HISTORY OF SPECIAL EDUCATION: IMPORTANT LANDMARK CASES

Abstract

Historically, children with disabilities received unequal treatment in the public education system throughout the United States. During and shortly thereafter the civil rights movement of the 1950s and 1960s, many parents and advocacy groups for children with disabilities began their own movement by using the U.S. federal court system to compel states to provide equal educational opportunities and rights for children with disabilities. The early cases discussed in this practice paper reflect how the legal rights of students with disabilities emerged, eventually leading to FAPE (free appropriate public education) and the enactment of the IDEA (Individuals with Disabilities Education Act) 20 U.S.C. Section 1400.

“In these days, it is doubtful that any child may be reasonably expected to succeed in life if he is denied the opportunity of an education. Such an opportunity, where the state has undertaken to provide it, is a right that must be made available to all on equal terms.”

– Chief Justice Earl Warren, writing for the unanimous United States Supreme Court, Brown v. Board of Education, 347 U.S. 483, 493 (1954)

Purpose

The purpose of this practice paper is to provide a brief examination and overview of the history of early disability litigation by focusing on the foundational cases that paved the way for the right to education of children with disabilities. The cases that will be discussed include:

  • Brown v. Board of Education, 347 U.S. 483 (1954)
  • P.A.R.C v. Pennsylvania, 343 F. Supp. 279 (E.D. Pa. 1972)
  • Mills v. Board of Education of the District of Columbia, 358 F. Supp. 866 (D.D.C. 1972)
  • Board of Education v. Rowley, 458 U.S. 176 (1982)
  • Honig v. Doe, 484 U.S. 305 (1988) and
  • Timothy W. v. Rochester, New Hampshire, School District, 875 F.2d 954 (1st Cir. 1989)

Constitutional Right to Education: A Misnomer

To most Americans, there is a common misconception that providing a child with the right to a public education is guaranteed by the Constitution of the United States of America. This is incorrect. Education is the responsibility of the states.

“The Tenth Amendment of the U.S. implies that education is the responsibility of the state government. That education is a state – not federal matter – was seen as essential by the founders of this country. This was because state governments were seen as being closer and more connected to the needs of the people.” Yell, M. L., Rogers, D. & Rogers, E. L.  (1998); see also, The legal history of special education: What a long strange trip it has been, Remedial and Special Education19, 219-228.

Despite the lack of an inherent federal right to public education, the United States Supreme Court in the early disability cases applied the due process and equal protection clause of the 14th Amendment to compel states to not “deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.” U.S. Constitution, Amendment 14.

Exclusion Was the Rule

Prior to the foundational disability rights cases being decided, exclusion of students with disabilities was the rule across the United States. One of the earliest reported cases that supported the philosophy of excluding students with disabilities was decided in 1893, where the Massachusetts Supreme Court upheld the “expulsion of a student solely due to poor academic ability” on the ground that the student was too “weak minded” to profit from instruction. Watson v.  City of Cambridge (1893); see also Principal Web Exclusive, “The Evolution of Special Education,” Keli J. Esteves and Shaila Rao, November/December 2008, pg 1.

Nearly thirty years later in 1919, the Wisconsin Supreme Court, in ordering the exclusion of a child from public school, held that “the very sight of a child with cerebral palsy will produce a depressing and nauseating effect” upon others. Beattie v. Board of Ed. of Antigo, 169 Wis 231, 232, 172 N.W. 153 (1919); see generally, Wrightslaw.com. Even the Supreme Court of the United States, on the issue of involuntary sterilization, ruled that “[i]t is better for all the world, if instead of waiting to execute degenerate offspring for crime, or to let them starve for their imbecility, society can prevent those who are manifestly unfit from continuing their kind … Three generations of imbeciles are enough.” Justice Oliver Wendell Holmes – Buck v. Bell, 274 U.S. 200 (1927). Throughout U.S history, states consistently and routinely enacted state statutes and regulations that allowed school officials and administrators to exclude children with disabilities from receiving public education. All of this changed with the landmark U.S. Supreme Court decision, Brown v. Board of Education, 347 U.S. 483 (1954).

Brown v. Board of Education

Decided in 1954, the Brown decision ruled that segregation within public schools was illegal, thereby ending as a matter of law segregation based on race. The Brown case determined that the “separate but equal” doctrine established by the Court in Plessy v. Ferguson, in providing “separate education facilities” based race was, in fact, inherently unequal and violated the equal opportunity and due process clause of the 14th Amendment.

As relating to education rights, the Brown court held “education is perhaps the most important function of state and local governments … It is the very foundation of good citizenship” and “such an opportunity where the state has undertaken to provide it, is a right that must be made available to all on equal terms.” Id., at page 493.

Notably immediately after the Brown decision in 1954, the Executive Director of the then-named “National Association for Retarded Children,” Dr. Gunnar Dybwad, drew attention to the Supreme Court’s decision with parents and disability advocacy groups, suggesting that this historical case had huge potential and opportunities for children with special needs. See, http://www.disabilityjustice.org/right-to-education.

Based on the Brown decision, one of the first and early pieces of federal legislation that was established to provide federal aid to assist Local Education Agencies (LEA) in meeting the needs of “educationally deprived” children was the 1965 Elementary and Secondary Education Act (P.L. 89-10) (ESEA). Authorized for one year, the ESEA authorized federal funding to states to establish sponsoring institutions and centers for “children with handicaps.” ESEA was amended and improved for nearly over the next two decades until it was renamed the Individuals with Disabilities Education Act (IDEA) in 1990 and then reauthorized in 2004..

Extending Brown to Children with Disabilities: P.A.R.C. & Mills

There are two cases from the early 1970’s, P.A.R.C. and Mills, that used the Brown decision to specifically address the issue of education for children with disabilities. At this point in American history, unlike today, there were millions of children with disabilities that were either denied enrollment in public schools, insufficiently served by public schools or alternatively were sent to institutions of deplorable conditions. In both of these cases, the courts applied the Brown decision by using the due process clause of the 14th Amendment to provide parents of children with disabilities specific rights to challenge and strike down state law that denied their child from the right to a public education.

P.A.R.C v. Pennsylvania

In P.A.R.C., the Commonwealth of Pennsylvania argued that the exclusions of “retarded children” complained of are based upon four state statutes. The first state section provided, in part, that the state board of education is relieved from providing a public education to any child that a psychologist determines is “uneducable and untrainable.” The second section allowed the state to indefinitely “postpone” the admission to public school any child who has not attained the “mental age of five years.” The language of the third and four sections provided additional unreasonable excuses for the state board of education to deny disabled children the right to a public education.

Thomas Gilhool, is the attorney that represented the Pennsylvania Association for Retarded Children (P.A.R.C.). Attorney Gilhool relied on the Brown case to bring forth a class action for P.A.R.C. on behalf of 14 children with developmental disabilities. He argued that under PA state law, these children were denied access to public education based on these four state sections. The plaintiffs argued that, under Brown, their rights were violated under the equal protection clause and due process clause of the 14th Amendment.

The parties entered into a consent agreement, which was then approved by the District Court for the Eastern District of Pennsylvania. The court entered the consent agreement. Much of the court language used by the parties and the court in this case laid the framework for the rights which are now provided to children with disabilities within federal and state statutes under the IDEA. For example, in clause two of the consent agreement, we find the framework language to what is now referred to as an IEP meeting, as well as due process: “No child of school age who is mentally retarded or who is thought by any school official…or by his parents…to be mentally retarded, shall be subjected to a change in educational status without first being accorded notice and the opportunity of a due process hearing…” Clause three also provides court-made language that laid the groundwork for an IEP meeting. Most importantly, the consent agreement stated “Expert testimony in this action indicates that all mentally retarded persons are capable of benefitting from a program of education and training … It is the Commonwealth’s obligation to place each mentally retarded child in a free, public program of education and training appropriate to the child’s capacity.” This is, in part, the framework for FAPE and the IDEA.

Mills v. Board of Education of the District of Columbia

As the P.A.R.C. case was being decided in Pennsylvania, the Mills case was being decided in the District of Columbia. Mills expanded the ruling of P.A.R.C. beyond children with developmental disabilities to children with behavioral, mental, hyperactive and emotional disabilities from being denied placement in a public education.

Similar to P.A.R.C., the school system in Mills agreed that it had a legal obligation “to provide a publically supported education to each resident of the District of Columbia who is capable of benefiting from such instruction.” However, unlike P.A.R.C., the school system in Mills argued that it was incapable to do so because of lack of financial resources.

The court held that no child may be denied a public education because of “mental, behavioral, physical or emotional handicaps or deficiencies.” The court further provided that the defendant school system’s failure to provide an education could not be excused by claiming insufficient funds, specifically stating “if sufficient funds are not available to finance all of the services and programs that are needed and desirable in the system, then the available funds must be expended equitable in such a manner that no child is entirely excluded from a publicly supported education consistent with his needs and ability to benefit therefrom.”

Subsequent to P.A.R.C. and Mills, twenty-seven other federal courts followed these two decisions, which eventually lead to the federal legislature passing federal laws in which to guarantee a free appropriate public education for all children with disabilities. One of the federal laws that emerged from these decisions was the 1975 Education for all Handicapped Children Act, now called the Individuals with Disabilities Education Act (IDEA).

Under the IDEA, all public schools that accept federal funding must provide a free appropriate public education for children with disabilities. IDEA also requires that each child with a disability have an “individualized education program” (IEP) that must be implemented in the “least restrictive environment” (LRE). One of the very first cases that addresses the term “appropriate” is Board of Education v. Rowley, 458 U.S. 176 (982).

Board of Education v. Rowley

In Rowley, the Court further elaborated on what is deemed appropriate under FAPE. Amy Rowley was a deaf child that performed better than the typical child in her mainstream classroom and was easily advancing from grade to grade in LRE with the use of a FM hearing aid. During an IEP meeting, Amy’s parents requested the school district provide Amy with a qualified sign-language interpreter in all of her classes, asserting that under the IDEA, such measures were deemed “appropriate.” After losing at due process and the review levels, the Rowleys appealed to the U.S. District Court and won. The school district then appealed and the U.S. Court of Appeals for the Second Circuit affirmed the District Court’s decision whereby the school district then appealed to the U.S. Supreme Court.

The issue before the U.S. Supreme Court in Rowley is what is meant by the IDEA requirement to a free “appropriate” public education. After reviewing the legislative history and intent of the IDEA, the Court held “the intent of the Act was more to open the door of public education to handicapped children on appropriate terms than to guarantee any particular level of education … We conclude that the “basic floor of opportunity” provided by the act consists of access to specialized instruction and related services which are individually designed to provide educational benefit to the child.” Thus, the Rowley decision clarified that children with disabilities were entitled to “access” to an education that provided an “educational benefit.” A school district does not have to “maximize” each disabled child’s potential.

The Rowley decision also held that the “Procedural Safeguards” of the IDEA are just as equally important as the substantive program offered to the disabled child. Therefore, a court’s inquiry under the IDEA has two parts. First, whether the state complied with the procedural safeguard of the act. Second, whether the child’s IEP is reasonably calculated to enable the child to benefit from his educational plan. The Court also held that under the IDEA, the burden of proof is a preponderance of the evidence standard.

Honig v. Doe

The Honig decision is a landmark case in which the U.S. Supreme Court dealt with the issue of expelling a disabled child based on actions arising out of that child’s disability. In Honig, the Court ruled that a school district may not unilaterally exclude or expel a disabled child from the classroom setting for dangerous or disruptive conduct growing out of their disabilities.

The child in this case, John Doe, was a 17-year-old boy that had significant challenges in his ability to control his behavior, impulsivity and anger towards others. His grandparents argued that a child with a disability, who is disciplined based on actions arising out of that child’s disability, may not be subjected to school disciplinary actions including expulsion, without the right to due process under the IDEA. The court emphasized the importance of a school district following the procedural safeguards contained with the IDEA, which includes the right to due process and an IEP meeting.

The Honig case is a landmark decision because the Court created what is now known as the “ten-day rule,” which allows a school to only suspend a child for up to ten days without parental consent or court intervention. Moreover, the Court ruled that a student could not be removed from school if the inappropriate behavior is a result of their disability. Now, under the IDEA, a child may be expelled for up to ten days for disciplinary infractions and up to forty-five days for dangerous behavior involving weapons or drugs. However, if a school is seeking a change of placement, suspension or expulsion of a child in excess of ten days, an IEP meeting must be held to review the causal relationship between the child’s misconduct and his disability. This specific meeting has become known a “manifestation determination” review. From a clinical prospective, the Honig decision also gave rise to the need of BCBAs conducting what is known as a “functional behavioral assessment” or an FBA.

Timothy W. v. Rochester, New Hampshire, School District

The last landmark case in the context is special education law is the Timothy W. case. In this case, the plaintiff-appellant Timothy W appealed an order from the district court that held that a child that is profoundly handicapped is not eligible for special education if he cannot benefit from such education.

The First Circuit reversed the district court’s decision and stated that the purpose of the Education for All Handicapped Children Act is “to assure all handicapped children have available to them … a free appropriate public education which emphasizes special education and related services designed to meet their unique needs …”

In this case, Timothy W disabilities were severe. The school district argued that his disability was so severe that he was unable to benefit from any provided education. The Court held that the act provides for a zero-reject policy and that under the act such severally disabled children are in fact given the highest priority and protection under the act itself. Related services were also defined as equally important as special education needs. Thus, related services, such as OT, PT, SLP, AT, socialization, eating, dressing and daily living skills are all encompassed under related services within the act.

Conclusion

In conclusion, this practice paper addresses what are the landmark cases that helped to develop the educational rights of children with special needs and disabilities. As an attorney that exclusively represents children with special needs, it is up to us to help further expand and define these rulings to continue to improve and build upon our client’s rights to a free appropriate public education.