In the case of Rachel H., the court identified several factors which are critical in analyzing whether a school district’s placement recommendation complies with the least restrictive environment mandate. These factors are: 

1. Educational benefits available to the student with a disability in a general education classroom, supplemented with appropriate aids and services, as compared with educational benefits of a special education classroom; 
2. Nonacademic benefits of interaction with children who are not disabled; 
3. Effect on the teacher and the other students in the classroom of the presence of the student with disabilities in terms of disruptive behavior and/or undue consumption of the teacher’s time; 
4. Cost of mainstreaming a student with disabilities in a general education classroom as compared to the cost of placement of the student in a special education classroom.

No one single factor will determine whether the district has met the LRE mandate. For example, even if a student might make more progress on academic IEP goals in a special class, the IEP team should still consider the second factor regarding nonacademic benefit before determining placement. As long as the progress made is satisfactory, the educational benefit factor of Rachel H. is met, even if the progress is not the most that the student could make in another setting.

However, it is clear from court decisions issued since Rachel H. that if a student would not benefit from placement in a general education class or environment — that is, they would not progress toward meeting their IEP goals, which could include non-academic goals such as behavioral/adaptive, communication or social/emotional goals, — placement in a general education classroom may be difficult.^[1] Some educational benefit must occur. However, in California, the benefit that must occur in order for an IEP and placement to be appropriate is not substantial. The Court in Rachel H. stated: “The [IDEA’s] presumption in favor of mainstreaming requires that a [disabled] student be educated in a regular classroom if the student can receive a satisfactory education there, even if it is not the best academic setting for the child.”.^[2] Moreover, the determination of whether a student will make progress toward IEP goals must be made in the context of whether they will make progress if supplementary aids and services are offered to support the student in the general education environment.^[3]

In D.R. v. Redondo Beach Unified School District (9th Cir. 2023), the court reaffirmed the importance of considering a student’s progress toward their IEP goals when determining the least restrictive environment (LRE). The decision emphasized that the academic benefits of mainstreaming must be assessed in the context of the student’s individualized progress, not solely based on grade-level performance. This ruling clarified that substantial supplementary aids and services should be provided to help the student succeed in a general education setting. The case reinforces the principle that as long as the student is making meaningful progress toward their IEP goals which can include non-academic goals, with appropriate supports, removal from the general education classroom is not justified. The court reiterated that the LRE requirement should be met, even if the general classroom is not the optimal academic setting for the student, aligning with the earlier precedent established in Rachel H. and other cases. (D.R. v. Redondo Beach Unified Sch. Dist., 9th Cir. 2023).

1. See Hartmann by Hartmann v. Loudoun County Bd. of Educ., 118 F.3d 996 (4th Cir. 1997); Poolaw v. Bishop, 67 F.3d 830 (9th Cir. 1995); County of San Diego v. California Special Education Hearing Office, 93 F.3d 1458 (9th Cir. 1996).[↩]
2. 786 F. Supp. at 879.[↩]
3. 20 U.S.C. Sec. 1412(a)(5)(A); 34 C.F.R. Sec. 300.320(a)(4); Cal. Ed. Code Sec. 56345(a)(4).[↩]