In the case of Hartmann vs. Loudon County Board of Education, the plaintiff alleged that the defendant failed to educate Mark Hartmann, a student with autism, with non-handicapped children to the maximum extent appropriate. Mark Hartmann is an eleven-year-old child who has a developmental disorder characterized by significant deficiencies in communication skills, social interaction and motor control. He was joined in regular classroom during his pre school years at Butterfield Elementary, Illinois with self-contained classes as well.
He was provided with speech and occupational therapy while doing so. So, when they moved to Loudon County, Virginia, and his parents sent him to Ashburn Elementary he was placed at the regular education classroom based from his IEP at Illinois. Mark was provided with all the support including SPED Teacher, Special Aide, Therapist, etc. However eventually, Mark manifested episodes of behavioral problems such as screeching, hitting, pinching, kicking, biting and removing his clothes.
His IEP team declared that there was no academic progress noted for Mark in his stay with the regular classroom hence it has been proposed to place him in a specifically structured class at Leesburg Elementary. His parents refused to sign the new IEP and demanded court hearings against the Board due to failures of providing appropriate education in the least restrictive environment. The Hartmanns won the case on the basis that Loudon County failed to provide appropriate steps to try to include Mark in a regular class.
They also rejected the administrative findings that Mark could not receive significant educational benefit in a regular classroom. The district relied heavily on the reading of Mark’s experience in Illinois and Montgomery County, where he moved. Also, they regarded disruptive behavior as not a significant factor in determining the appropriate educational placement for a disabled child. However IDEA too expresses the relationship between local school authorities and a reviewing district court such that invitation to the courts is by no means to substitute their own notions of sound educational policy for those of the school authorities.
IDEA also notes that administrative findings are prima facie correct. IDEA also does no prohibit educators of the right to present professional judgment and although states have been tasked to give specialized instruction and other services, it is not required to furnish every special service necessary for the child. The appropriateness of Mark’s education becomes inappropriate when despite supplementary aides and services; his education is not achieved satisfactorily due to the severity of the disability.
The progress Mark was making at his speech therapy was due to its one on one setting. The Illinois report of his presumed progress was considered flawed. In consideration of Mark’s social skills that were due to interaction with non-disabled peers, this however cannot outweigh his failure to progress in academics in the regular classes. The Supreme Court in favor of the Loudon County Board of Education has therefore reversed the decisions of the district court. I feel that this case impacts on my understanding of the Least Restrictive environment.
Clearly, the case helped me clarify issues of appropriateness of education for disabled students, factors to consider in conducting assessments of the students, the relationship between behavior and academic performance vis a vis educational placement decisions, the significance of IEP as a basis for a student’s current performance, and most specially the smooth relationship between parents and educators in arriving at a common understanding for the benefit of the student.
This new knowledge is beneficial for me in two ways: in properly interpreting IDEA and in improving assessment of students so that proper IEP is made, appropriate educational placement is suggested and modified teaching strategies and methods are implemented.
This case has been important in public education in terms of determining proper relationships between local school authorities and district courts and in the consideration of evidences that are most significant to the case. Also, it created a new sentiment as regards the notion of LRE and FAPE, that mainstreaming favors educational benefit of the student but is not sufficient to attain so.
Courtney from Study Moose
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