In the case of Sacramento City Unified School District v. Rachel Holland, 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:
- Educational benefits available to the student with a disability in a regular classroom, supplemented with appropriate aids and services, as compared with educational benefits of a special education classroom;
- Nonacademic benefits of interaction with children who are not disabled;
- 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;
- Cost of mainstreaming a student with disabilities in a regular 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 Holland 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 Holland that if a student would not benefit from placement in a regular class or environment — that is, she would not progress toward meeting her IEP goals — placement in a regular classroom is unlikely. [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).] 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 Holland 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.” [786 F. Supp. at 879.] Moreover, the determination of whether a student will make progress
toward IEP goals must be made in the context of whether she will make progress if supplementary aids and services are offered to support the student in the regular environment. [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).]