CHARACTERISTICS OFAND STRATEGIES FORTEACHING STUDENTS

CHARACTERISTICS OF
AND STRATEGIES FOR
TEACHING STUDENTS WITH
MILD DISABILITIES
MARTIN HENLEY
Westfield State College
ROBERTA S. RAMSEY
Norwich University
ROBERT F. ALGOZZINE
The University of North Carolina at Charlotte
Library of Congress Cataloging in Publication Data
Henley, Martin, 1943-
Characteristics of and strategies for teaching students with mild
disabilities / Martin Henley, Roberta S. Ramsey, Robert F. Alg
ozzine. — 6th ed.
p. cm.
Includes bibliographical references and index.
ISBN-13: 978-1-323-45488-6
ISBN-10: 1-323-45488-8
1. Learning disabled—
United States. 2. Mainstreaming in education—
United States. 3. Behavior modification—
United States. I. Ramsey, Roberta S. II. Algozzine, Robert. III.
Title.
LC4705.H46 2009
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2008022251
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FOUNDATIONS OF SPECIAL EDUCATION FOR STUDENTS
WITH MILD DISABILITIES
ADVANCE QUESTIONS
Answer the following questions as you read this chapter:
1. What factors led to the development of special education?
2. What are the key principles that drive special education today
?
3. Why do some students receive special education?
4. Who is eligible for special education?
5. What are mild disabilities?
6. What are the advantages and disadvantages of classifying stu
dents for special education?
7. How do school personnel decide what special education servi
ces are appropriate for students with mild disabilities?
8. What are some key differences between general and special e
ducation?
VIGNETTE: JAKE, MARY, FELIPE
Jake always seems to be one step behind the other students in hi
s 7th-
grade class. Despite the slowness that is a part of Jake’s perfor

mance and social development, his teacher enjoys having him in
class. Because Jake is talkative with a good sense of humor, ma
ny of his schoolmates enjoy helping him. Jake’s teacher likes te
aching him because he responds favorably to efforts to help him
develop new skills. Jake’s classroom performance is similar to
many students with mild intellectual disability.
Jake’s class contains a mixture of students who are easy to teac
h and students who are hard to teach. Mary is one of the difficul
t kids. When she was younger she was diagnosed as “hyperactiv
e,” and she was put on medication to control her behavior. She c
omes from a home where both parents work hard to maintain a c
omfortable lifestyle. There is a lot of pressure put on Mary to su
cceed. Both of her parents are upwardly mobile professionals.
Mary does not trust adults and often takes her anger out on her c
lassmates. When she is not physically disrupting the classroom,
Mary is socially withdrawn, isolated, and unhappy. Mary’s teac
her believes that Mary is emotionally disturbed.
Felipe also is difficult to teach—
not because of what he does, but because of what he does not do
. Felipe does not read or write as well as his 7th-
grade classmates. He has never done well in reading, but his sco
res on ability tests and tests of achievement in other areas (e.g.,
mathematics) have always been average when compared to his p
eers. Now that Felipe is in junior high school, his difficulties ar
e particularly troublesome, because he is expected to read and c
omplete homework assignments in English, history, science, psy
chology, and economics. Felipe appears to have a learning disab
ility.
Each of these students—Jake, Mary, and Felipe—
is difficult to teach. They are constantly at risk of failing, and t
hey are potential school dropouts. Jake, Mary, and Felipe have
mild disabilities that are interfering with their progress in schoo
l.
Now that you have read the vignette about Jake, Mary, and Feli
pe, see how many problem-
solving questions you can answer. For those questions you cann

ot readily answer, try to find some additional information to use
in answering them as you read the chapter. The experiences of
Jake, Mary, and Felipe are typical of students with mild disabili
ties.
1. What should be done to help students like Jake, Mary, and Fe
lipe?
2. Who should teach them?
3. Should public schools provide special education services for
students with learning problems like Jake, Mary, and Felipe?
4. What expectations would you have for students like Jake, Ma
ry, and Felipe if you were teaching in their junior high school?
5. What is a mild disability?
6. Should students with mild disabilities be included in classes
with students without disabilities?
Every classroom contains students like Jake, Mary, and Felipe.
Helping students with learning problems is part of the motivatio
n that stimulates many to become teachers. As one experienced t
eacher put it, “some teachers like the underdog.” The purpose of
special education is to help students achieve success in school.
Special educators and their general classroom peers want to see
all students stay in school, graduate, and succeed in life, but bec
ause of differences between the two systems of education, they
sometimes work at cross-
purposes. When special and general educators communicate and
share responsibility for educating students with special needs, e
verybody benefits.
THE ROOTS OF SPECIAL EDUCATION
Origins of the national education system in America date from t
he colonial days. Early schools educated a select, limited segme
nt of the population—white, male children of upper-
class families (Smith, Price, & Marsh, 1986). Before 1815, scho
ols serving this small proportion of school-
aged youth were primarily church sponsored.
Public support of schools by local taxation began during the firs
t half of the nineteenth century. Children previously excluded fr

om schooling—
middle class, poor, female, or culturally different—
were included. During the mid-
nineteenth century, states began enacting compulsory education
laws (e.g., Rhode Island in 1840, Massachusetts in 1852). A cha
nge in the values and economic thinking of U.S. society was refl
ected by this Common School Movement.
These early common schools educated students of all ages in the
same classroom. In the one-
room schoolhouse, students of different ages, different abilities,
and different backgrounds learned side by side. Horace Mann, t
he architect of American public education, believed universal ed
ucation was the great equalizer. Cremin (1961) characterized thi
s early vision:
Mann’s school would be common, not as a school for the comm
on people—for example, the nineteenth-
century Prussian Volksschule—
but rather as a school common to all people. It would be open to
all, provided by the state and the local community as part of th
e birthright of every child. It would be for rich and poor alike, n
ot only free but as good as any private institution. It would be n
onsectarian, receiving children of all creeds, classes, and backgr
ounds. (p. 10)
Mann’s humanitarian ideal began to take hold, and by 1860, a m
ajority of the states had established public school systems. Thro
ughout this period of rapid growth, Mann advised that instructio
n be adapted to meet the needs of children who differed in temp
erament, ability, and interests.
As the United States grew, the one-
room schoolhouse was replaced by graded elementary, middle, a
nd high schools. Explicit academic requirements were establishe
d for each grade level of the common public school. Students w
ere taught a specific curriculum and that curriculum was organiz
ed into graded units. Educators believed that grouping students
by age would make the task of teaching easier (Sarason & Doris
, 1979; Ysseldyke & Algozzine, 1982; Ysseldyke, Algozzine, &

Thurlow, 2000). Achievement was determined by how well chil
dren learned the predetermined, graded curriculum. This curricu
lum-
centered characteristic of the new schools made it difficult for
many children to keep pace (Smith, Price, & Marsh, 1986; Yssel
dyke & Algozzine, 1984).
SPEEDBUMP—
Did you know that summer vacations originated so students coul
d work the family farm during peak growing times?
Immigration and compulsory school attendance broadened the sc
hool-
aged population to a larger, more diverse membership. Cultural
and ethnic differences in students created a mismatch between t
eacher expectations and student performance. Some children ada
pted to school and learned; others dropped out. Many children w
orked in factories; others took to the streets. Few of the absent s
tudents were missed. Little concern was shown for children with
learning problems and what we now refer to as “at-risk youth.”
The influence of social reformers, such as Jane Addams, encour
aged the establishment of alternative instructional programs for
“special cases.” The superintendent of the Baltimore schools wr
ote, “Before the attendance laws were effectively enforced there
were as many of these special cases in the community as there i
s now; few of them, however, remained long enough in school t
o attract serious attention or to hinder the instruction of the mor
e tractable and capable” (Van Sickle, 1908–1909, 102).
Early public educational programs offered two choices. Students
either received and profited from instruction in lock-
step, curriculum-
centered classes or they were placed in special classes. Many ad
ministrators believed that these first special education programs
were proper preparation for institutionalization. In a speech to t
he National Education Association, E. R. Johnstone (1908) state
d that the special education class
must become a clearing-
house. To it will be sent the slightly blind and partially deaf, bu

t also incorrigibles, the mental deficients, and the cripples.…Th
e only thing to do is to give them the best of care and training p
ossible. Keep them in the special classes until they become too
old for further care in school, and then they must be sent to the
institutions for safety. (Johnstone, 1908, 114–118)
A few early special programs were set up for children with spec
ific disabilities, such as deafness or blindness. However, many e
arly public school special classes were repositories for diverse y
oungsters who did not fit into the general classroom. In 1909, El
izabeth Farrell described students in her first special education
class in New York City:
The first class was made up of the odds and ends of a large scho
ol. There were the over-age children, the so-
called naughty children, and the dull, and stupid children. They
were taken from any and every school grade. The ages ranged fr
om eight to sixteen years. They were the children who could not
get along in school. They were typical of a large number of chil
dren who even today are forced directly or indirectly out of sch
ool; they were the children who were interested in street life; m
any of them earned a good deal of money in one way or another.
While some of them had been in trouble with the police, as a cl
ass they could not be characterized as criminal. They had varied
interests but the school, as they found it, had little or nothing f
or them. (Farrell, 1909, 91–96)
From the first decades of the twentieth century until the mid-
1970s, students who did not fit in general education classes wer
e ignored, placed in isolated special classes, or transferred to st
ate institutions.
SPEEDBUMP—
There is a saying “the more things change, the more they remain
the same.” Unfortunately, there are still programs where studen
ts are separated from their peers because they don’t fit in. Many
of them are like the streetwise type of youngster taught by Eliz
abeth Farrell over a hundred years ago.
In Pennsylvania, legislation provided for the exclusion of specif
ic children from school. Children evaluated as uneducable becau

se of below-
average IQ scores were assigned to the Department of Public W
elfare for training in state-
run institutions. Most notable about the process of classifying a
nd rejecting students who didn’t fit the standard public school c
urriculum was the lack of due process in educational decisions.
In 1970, the Task Force of Children Out of School studied the B
oston Public School System. The Task Force report—
The Way We Go to School: The Exclusion of Children in Bosto
n—
found over ten thousand students excluded from public school cl
assrooms because they didn’t match school standards for the nor
mal student. Patricia Reilly, age 16, was told to leave school be
cause she was pregnant. Kathy Fitzgerald, age 9, was excluded f
rom public school because she had a seizure disorder (i.e., epile
psy). Richard, 11 years old, was placed in a special class for the
retarded because he was emotionally disturbed and no other pro
gram was available. These children were denied the right to an a
ppropriate education because they were different. In 1974, the U
.S. Congress estimated that over a million school-
aged youngsters were denied a proper education in this country’
s schools.
The experience of being treated differently because one does no
t fit into society’s vision of what is normal and accepted is diffi
cult. Many move to the “land of opportunity,” to “the other side
of the tracks,” to “the better part of town,” or to “a good school
” to overcome discrimination and to build a “better life” for the
mselves and their children. They hope to reclaim the dignity the
y are entitled to as human beings and citizens of a country for w
hich dreams and ideals of individualism, equal opportunity, nati
onalism, and success prevail and are the basis for fundamental h
uman rights and continuing social responsibilities. Too often it
simply doesn’t work out that way. Too often, differences and di
versity that should be celebrated are the source of disparaging r
emarks, continuing intolerance, and disenfranchising treatment.
SPEEDBUMP—

Having a disability is just another way of being different.
How could a nation based on equal opportunity for all its citizen
s support discriminatory practices toward children? The answer
is found in attitudes. Prejudice, like creeping shadows, can take
many forms. The public school system mirrors society. Schools
reflect the attitudes and prejudices of teachers, administrators, a
nd parents. Students with disabilities have special needs, and in
the past those special needs have been used as a rationale to exc
lude them from mainstream life in American schools.
Education once intended for a small, elite sector of the populati
on now is mandated for all children. During the past century, th
e curriculum-
centered format of public schools has remained static while the
needs of students have changed significantly. School dropouts,
discipline problems, low achievement, and increased referrals to
special education are a concern to educators and the public at l
arge.
SPEEDBUMP—
Passing standardized testing as a graduation requirement has cre
ated difficulties for many students, including those with special
needs.
Diversity of students, simply defined as coming from a different
background than your peers, is at odds with a system of educati
on that requires conformity and assimilation of an unyielding cu
rriculum. Smith-
Davis (1989a) identified some important events and acts of legis
lation that enhanced diversity. The Brown v. Topeka Board of E
ducation decision in 1954 radically altered the national school p
opulation. This landmark case, acted upon by the U.S. Supreme
Court, decreed that “segregated but equal” school facilities for
black and white schoolchildren were discriminatory and unconst
itutional. Brown v. Topeka Board of Education reversed a prior
decision rendered in Plessy v. Ferguson in 1894 that legalized s
eparate schools based on racial lines.
The Civil Rights Act of 1964 gave support to advocates who pus
hed for the inclusion of students with disabilities in public scho

ols (Smith-
Davis, 1989a, b; Smith, Price, & Marsh, 1986; Ysseldyke & Alg
ozzine, 1990). Mainstreaming, a term used to promote the integr
ation of school-
aged youth with disabilities into classrooms with their peers wit
hout disabilities, followed on the heels of successful efforts to d
einstitutionalize programs for adults and children with disabiliti
es. Placement of youth and adults with moderate and severe disa
bilities within community settings dramatized their capability to
live normal lives. These changes diversified the student populat
ion in the nation’s schools and emphasized the need for schools
to accommodate children with special learning needs (Ysseldyk
e, Algozzine, & Thurlow, 1983; 2000), yet changes in public sc
hool practices toward students with disabilities have been slow t
o come. For instance, the steady increase each year in youngster
s identified with mild disabilities and placed in special program
s is testimony to the intractability of a system of education that
looks first to blame the student for failure.
SPEEDBUMP—
If you like to look at a situation from different points of view, y
ou will like special education. It is interdisciplinary—
combining such areas as politics, law, medicine, and psychology
.
DIVERSITY
In 1987, 47 percent of the workforce was comprised of white A
mericans; by the mid-twenty-
first century 85 percent of new workers will be African America
ns. In the year 2020, almost half of the school-
aged population will be young African Americans (Pallas, Natri
ello, & McDill, 1989). This “browning of America” is a reality t
hat signals profound change in U.S. culture. Multicultural educa
tion, with its attendant emphasis on gender, race, and bilinguali
sm is aimed at preparing today’s youth for a future characterize
d by diversity. Ford (1992) defines multicultural education as sc

hool “practices and policies that transform the school so that ma
le and female students, social class, racial, and ethnic groups wi
ll experience an equal opportunity to learn” (p. 108).Multicultur
al Family Adaptation.
Family adaptation researchers are just beginning to recognize cu
lture as an important variable for exploration (Bennett, DeLuca,
& Allen, 1996; National Research Council, 2001; Seligman, 19
99). For example, African American families whose religions str
ongly influence their family traditions may appraise disability p
ositively. “The optimism and belief that all children are importa
nt typifies African American culture and is reflected in family f
unctions and reinforced in church and religious beliefs” (Rogers
-
Dulan & Blacher, 1995, 234). Within the Native Hawaiian cultu
re, the spiritual orientation toward life may influence families t
o think that having a child with behavior disorders is “normal” a
nd that this child is a valued member of the community, regardl
ess of disability. The Native American assimilation of individua
ls with disabilities into the mainstream culture is reflected in th
e absence of native language “labels” or “classifications” for dis
abilities such as autism. Rather, descriptive statements commonl
y are used such as those by some Navajos, including “she runs a
way,” or “he gets excited,” or “he’s in his own world” (Connors
& Donnellan, 1998, 171).
Social support is defined as the community supports and resourc
es “that the family may use to cope with a stressor situation” (M
cCubbin, McCubbin, Thompson, & Thompson, 1998, 20). Social
support may include people, such as family and friends, and or
ganizations, such as schools, churches, parent and sibling suppo
rt groups, and medical services. Social support mediates the effe
cts of the stressor on the health of the family (see McCubbin et
al., 1998). The strong familial support needed to raise a child wi
th behavior disorders is found in many cultures.
Native Hawaiians share a common concern for the well-
being of all individuals in the tribal structure, which encompass
es the immediate and extended family (McCubbin et al., 1998).

Similarly, the foundation of the family structure in Filipino Am
erican families is built on cooperation and family support and al
legiance, in which individual desires are sacrificed for the benef
it of the family (McCubbin et al., 1998). Many individuals withi
n the African American culture perceive caregiving for a depend
ent member as a responsibility to be shared among siblings and
extended family members (Pruchno, Patrick, & Burant, 1997).
Fear of stigma also has been reported in African American famil
ies (Pruchno et al., 1997), who tend to access services provided
by professional organizations less frequently than the majority c
ulture (see Pruchno et al., 1997) and only after relying on famil
y, friends, religion, and church support. The concept of “familis
mo” in Hispanic families relates to strong family cohesion. This
familial cohesion may circumvent the use of professional servic
es if family values conflict with standards of the majority cultur
e (Blacher, Lopez, Shapiro, & Fusco, 1997). When Hispanic mot
hers of children with disabilities believe in their spiritual role a
s “sacrificing mothers,” and if they receive strong support from
their extended family, they may take upon themselves the respo
nsibility of raising their child with little organizational support
(Bailey, Skinner, Rodriguez, Gut, & Correa, 1999).
A diversity issue that affects all populations is lack of equal rig
hts for women. Even though men and women have equal ability,
men continue to be paid higher salaries and have easier access t
o promotion. Stereotypes about women begin in infancy, with pi
nk birth ribbons signifying daintiness and beauty. These initial
views are strengthened throughout childhood through toys, sport
s, and leisure activities. Consider a 9-year-
old boy who chooses ballet over baseball or a 10-year-
old girl who wants to play football. These youngsters will face
opposition and ridicule as they attempt to oppose gender barrier
s. Look around your education classes. If you are an elementary
or early childhood major, you probably have five times more fe
males than males in your class. Why do more women than men s
elect education as a major? An analysis of explanations will hig
hlight some of the gender barriers girls and women must overco

me in order to achieve an equal position in U.S. society.
SPEEDBUMP—
One of the major issues educators as well as citizens will be dea
ling with in the future will be whether English should be the “of
ficial” language of the United States. What do you think?
As the debates continue about how diversity issues should be de
alt with, the major hurdle to the educational progress of many p
eople of color continues to be poverty. Hu-De-
Hart (1993) succinctly illustrates the chasm that separates rich a
nd poor in the United States: “Today 1 percent of the population
of the United States has ‘gained control’ of more of the nation’
s wealth than the bottom 90 percent. This situation parallels the
stark and painful inequality in much of the Third World” (p. 51)
. Multicultural proponents point to inequities of school funding
as evidence that today’s poor schoolchildren (many of whom are
minorities) are at a distinct disadvantage in their preparation fo
r tomorrow’s workplace. Property taxes fund schools. Children
who live in destitute communities are unable to break the cycle
of poverty because their education is as bleak as their neighborh
oods.
African American children, particularly males, are overrepresen
ted in special education programs for students with mild intellec
tual disability and emotional disturbance. Paradoxically, female
s and children with limited English proficiency (e.g., Hispanic)
are underrepresented in special education programs. This trend
of over-
and underrepresentation means that many African American chi
ldren may be inappropriately placed (see Lloyd Dunn’s remarks
in Chapter 3, Mild Intellectual Disability), while females and Hi
spanic students who require special education are overlooked. T
he uneven distribution of students in special education has creat
ed a confusing picture about the educational needs of females of
all races: African Americans, Hispanics, and Native Americans.
In an optimistic future scenario, the United States will be built
on a strong foundation of respect for individual differences. The
positive outcomes of multicultural education could help allevia

te sexism and racism. In such a society all individuals regardles
s of gender, ethnic origin, sexual preference, or disability will h
ave an equal opportunity to succeed. As educators, the choices
we make now will determine our ability to adapt to fundamental
changes in U.S. society.
ENDING HANDICAPPISM
Advocates for individuals with disabilities have used the word h
andicappism to refer to the disabling perception that a person is
incompetent because of a physical or psychological impairment.
When asked about their most difficult adjustments, adults with
disabilities invariably comment about dealing with stereotypes.
For example, friends and neighbors may refer to Elise Jones, wh
o has a visual impairment, as “poor, blind Elise!” Condescendin
g remarks about individuals with disabilities may be masked as
sympathy, but the message is a clear illustration of handicappis
m. In fact, Elise’s visual impairment is only a part of her indivi
duality, not the sum total of who Elise is as a person.
Sooner or later, most of us will experience a disability. Old age,
injuries, or illness are inescapable aspects of the human conditi
on. Although the idea that at some point in your life you will ex
perience a disability might seem remote, the simple truth is that
we are not talking about infrequent or isolated cases. The numb
er of U.S. citizens with disabilities is equal to the combined pop
ulation of New York City, Los Angeles, Chicago, and Miami.
Individuals with disabilities are people first and people with a d
isability second. The label assigned to their disability should no
t be used to replace all their other characteristics. Franklin D. R
oosevelt guided the United States through the Second World Wa
r from the vantage point of a wheelchair. Einstein was considere
d too slow to attend school with his peers. Thomas Edison had a
learning disability. These extraordinary people were not limited
by their disabilities. Throughout this book, we highlight the ind
ividual first and the disability second by our phrasing “student
with a disability.” We do this because language shapes expectati
ons and expectations shape actions. Our persistent theme is that

students with mild disabilities are more like their peers than diff
erent from them.
SPEEDBUMP—
Your language, your expectations, and your actions when you te
ach students with mild disabilities will determine their success
or failure. Remember, a disability is a problem that can be overc
ome; don’t handicap your students by limiting your expectations
for their personal and academic growth.Litigation and Legislati
on
Prior to the early 1970s, handicappism, the notion that individua
ls with disabilities were severely limited in their ability to learn
, was the predominant educational perspective. Most notable ab
out this view was that the lack of due process afforded students
when educators either excluded them from school or placed the
m in dead-
end special classes. Due process is a constitutional right guarant
eed by the Fourteenth Amendment. During the 1970s, concern a
bout the legal rights of students with special needs spurred seve
ral significant class action suits that challenged school evaluatio
n and placement practices. A class action suit is litigation on be
half of a class or group of individuals. For example, when a sma
ll group of students who were classified as mentally retarded wo
n a class action suit, all other students with intellectual disabilit
y within the court’s jurisdiction benefitted.
SPEEDBUMP—
A class action suit affects all individuals who are in the same “c
lass” as the litigants. Can you think of any other class action sui
ts that have influenced public policy?
In Diana v. California State Board of Education (1970), the issu
e of Mexican American student overrepresentation in special cla
sses for students with mild intellectual disabilities was addresse
d. The plaintiffs were nine children who came from homes wher
e Spanish was the primary language. The class action suit allege
d that Mexican American students had been improperly categori
zed as mildly retarded on the basis of invalid IQ testing. In a co
nsent agreement, the opposing parties agreed that schoolchildre

n should be tested in their native language. This case laid the gr
oundwork for future lawsuits based on cultural bias in education
al evaluations.
The following year, 1971, fourteen families sued the state of Pe
nnsylvania on the basis that their children with intellectual disa
bility were denied equal access to a public education. This case,
Pennsylvania Association for Retarded Children (PARC) v. Co
mmonwealth of Pennsylvania, was prompted by the state policy
of denying a public education to youngsters with intellectual dis
ability. During the legal proceedings, parents described their fut
ile attempts to fight a system that arbitrarily and callously exclu
ded their children from school.
Nancy Beth Bowman was expelled from kindergarten because sh
e wasn’t toilet trained. The 15-year-
old daughter of Leonard Kalish was never allowed to enroll in s
chool. It cost him $40,000 to have her educated in private schoo
ls. The parents of David Tupi said their son was expelled from s
chool without notice. One morning the school bus simply stoppe
d coming to pick him up. The three-
judge panel, in a consent decree, ruled that the state could not p
redetermine educability. In their decision the judges stated that
Pennsylvania must:
1. Admit all children with intellectual disability into public sch
ool.
2. Place students with intellectual disability in general classroo
ms when possible.
3. Make all school records accessible to parents.
4. Provide preschool programs for children with intellectual dis
ability when such programs were available to nondisabled childr
en.
5. Precede all placement decisions with a hearing to allow paren
tal participation and consent.HIGHLIGHT 1.1
Francis enjoyed going out to eat with his friends. However, he o
ften encountered difficulties because few restaurants were acces
sible to his wheelchair. Curbs, narrow doors, stairs, and small p
ublic restrooms were all obstacles for Francis. One evening Fra

ncis and his friends were ordering dinner. When the waitress ca
me to Francis, she asked one of his friends, “What would he lik
e to eat?” The waitress assumed that because Francis was in a w
heelchair he was incapable of ordering his own dinner! Just as p
hysical obstacles impaired Francis’s ability to live a normal life
, so did stereotypes by well-
meaning but thoughtless people. A disability is born but society
handicaps.
The PARC decision emphasized the due process rights of parent
s to review and challenge placement decisions regarding their c
hildren.
In Mills v. The Board of Education of the District of Columbia (
1972), litigants challenged the exclusion of children identified a
s mentally retarded, emotionally disturbed, learning disabled, vi
sually impaired, hearing impaired, and physically disabled from
Washington, D.C., schools. As in the PARC case, Mills demons
trated the unconstitutionality of school exclusion procedures. B
oth the PARC and Mills “right to education” cases highlighted t
he right of students with disabilities to due process in education
al decisions.
By 1973, 31 similar court cases constituted a groundswell of pol
itical activism on behalf of students with disabilities (Taylor &
Searle, 1987). It was clear to Congress that schools could no lon
ger be allowed to violate the Fourteenth Amendment rights of st
udents with disabilities. The Fourteenth Amendment states that
“no state shall make or enforce any law which shall abridge the
privileges or immunities of citizens of the United States; nor sh
all any state deprive any person of life, liberty, or property with
out due process of law.”
FEDERAL LAWSSection 504 of the Rehabilitation Act of 1973
Several federal laws have significantly influenced the education
of children and adults with disabilities. The first of these is the
Rehabilitation Act of 1973 that protects individuals from being
discriminated against because of a disability. Within public sch
ools Section 504 of this law is often used to provide support ser

vices for students who have a disability that is not included in t
he Individuals with Disabilities Education Act (IDEA), for insta
nce students with ADHD.
Section 504 of the Rehabilitation Act of 1973 states:
No otherwise qualified individual with a disability… shall, solel
y by reason of her or his disability, be excluded from participati
on in, be denied the benefits of, or be subjected to discriminatio
n under any program or activity receiving Federal financial assi
stance. … [Language of Section 504 of the Rehabilitation Act: 2
9 U.S.C. 794(a) (1996)]
Section 504 is a brief but powerful provision of the Rehabilitati
on Act of 1973 that extends to individuals with disabilities the s
ame kind of protection extended to individuals discriminated ag
ainst on the basis of race and gender (Huefner, 2000). Originall
y targeted at employment discrimination, the scope of Section 5
04 is broad, addressing protection in many areas (e.g., public sc
hool education, higher education, social services, health care, tr
ansportation). Because most school districts in the country acce
pt federal funds, public education was greatly influenced by Sec
tion 504.
The relationship between Section 504, the Americans with Disa
bilities Act (ADA), the Individuals with Disabilities Education
Act (IDEA), and the No Child Left Behind Act is presented in T
able 1.1. Basically, any person with a disability (i.e., physical o
r mental impairment that limits major life activities) is eligible f
or Section 504 assistance. This group is broader than the group
eligible for federal assistance under IDEA and special education
guidelines (i.e., all students with disabilities receiving assistan
ce under IDEA are eligible for 504 support, but not all students
receiving assistance under 504 are eligible for support under ID
EA).
TABLE 1.1 Scope of Key Legislation Affecting Students with D
isabilities
INDIVIDUALS WITH DISABILITIES EDUCATION IMPROVE
MENT ACT (IDEA) (2004)
This education act reauthorizes federal financial assistance to st

ate and local education agencies to guarantee special education
and related services to eligible children with disabilities.
Who is protected?
Children ages 3–
21 who are determined by a multidisciplinary team to be eligibl
e within one or more of 13 specific categories of disability and
who need special education and related services. Categories incl
ude autism, deafness, deaf-
blindness, hearing impairments, intellectual disability, multiple
disabilities, orthopedic impairments, other health impairments, s
erious emotional disturbance, specific learning disabilities, spee
ch or language impairments, traumatic brain injury, and visual i
mpairment.
Responsibility to provide a free appropriate public education (F
APE)?
A FAPE is defined to mean special education and related servic
es. Special education means “specially designed instruction, at
no cost to the parents, to meet the unique needs of the child wit
h a disability….” Related services are provided if required for t
he students to benefit from specially designed instruction. State
s are required to ensure the provision of full educational opport
unity to all children with disabilities. IDEA requires the develo
pment of an individualized education program (IEP) document
with specific content and a required number of specific particip
ants at an IEP meeting.
What are the procedural safeguards?
IDEA requires written notice to parents regarding identification,
evaluation, and/or placement. Further, written notice must be m
ade prior to any change in placement. The act delineates the req
uired components of the written notices.
What is the due process?
IDEA delineates specific requirements for local education agenc
ies to provide impartial hearings for parents who disagree with t
he identification, evaluation, or placement of a child.
NO CHILD LEFT BEHIND ACT (2002)
Signed into law in 2002, this new law contains sweeping change

s in the Elementary and Secondary Education Act. The act conta
ins four basic education reform principles.
Responsibility to provide a system for educational accountabilit
y?
States create their own standards for what students should learn
in each grade. Beginning in 2002, states began testing students i
n grades 3–5, 6–9, and 10–
12. By 2005, tests were administered in grades 3–
8 in math and reading. All students including those with mild di
sabilities are to be held to the same curriculum and assessment s
tandards.
Who is protected?
Federal aid is contingent on an increase in proficiency in math,
reading, and science among all students. States must maintain g
oals and assess results for various categories of students based o
n poverty, ethnicity, disability, and limited English proficiency.
Students attending Title I schools that fail to improve have the
option to attend a better school in the same district.
Schools have more flexibility in allocating resources and teache
r professional development. Students who choose to attend persi
stently failing schools can use Title I funds to obtain supplemen
tal educational services from public or private sectors.
AMERICANS WITH DISABILITIES ACT OF 1990 (ADA)
This act is a civil rights law to prohibit discrimination solely on
the basis of disability in employment, public services, and acco
mmodations.
Who is protected?
Any individual with a disability who (1) has a physical or menta
l impairment that substantially limits one or more life activities;
(2) has a record of such an impairment; or (3) is regarded as ha
ving such an impairment. Further, the person must be qualified f
or the program, service, or job.
APE)?

However, ADA protections apply to nonsectarian private school
s, but not to organizations or entities controlled by religious org
anizations and ADA provides additional protection in combinati
on with actions brought under Section 504 and IDEA. Reasonabl
e accommodations are required for eligible students with a disab
ility to perform essential functions of the job. This applies to an
y part of the special education program that may be community
based and involve job training/placement.
The ADA does not specify procedural safeguards related to spec
ial education; it does detail the administrative requirements, co
mplaint procedures, and the consequences for noncompliance, re
lated to both services and employment.
The ADA does not delineate specific due process procedures. Pe
ople with disabilities have the same remedies that are available
under Title VII of the Civil Rights Act of 1964, as amended by t
he Civil Rights Act of 1991. Thus, individuals who are discrimi
nated against may file a complaint with the relevant federal age
ncy or sue in federal court. Enforcement agencies encourage inf
ormal mediation and voluntary compliance.
SECTION 504 OF THE REHABILITATION ACT OF 1973
This is a civil rights law to prohibit discrimination solely on the
basis of disability in programs and activities, public and privat
e, that receive federal financial assistance.
Who is protected?
Any person who (1) has a physical or mental impairment that su
bstantially limits one or more major life activities, (2) has a rec
ord of such an impairment, or (3) is regarded as having such an
impairment. Major life activities include walking, seeing, hearin
g, speaking, breathing, learning, working, caring for oneself, an
d performing manual tasks.
APE)?
An “appropriate” education means an education comparable to t
hat provided to students without disabilities. This may be define

d as regular or special education services. Students can receive r
elated services under Section 504 even if they are not provided
any special education. Section 504 does require development of
a plan, although this written document is not mandated. The IEP
of IDEA may be used for the Section 504 written plan. Many ex
perts recommend that a group of persons knowledgeable about t
he students convene and specify the agreed-upon services.
Section 504 requires notice to parents regarding identification, e
valuation, and/or placement. Written notice is recommended. No
tice must be made only before a “significant change” in placeme
nt. Following IDEA procedural safeguards is one way to meet S
ection 504 mandates.
Section 504 requires local education agencies to provide imparti
al hearings for parents who disagree with the identification, eva
luation, or placement of a student. It requires that parents have
an opportunity to participate in the hearing process and to be re
presented by counsel. Beyond this, due process details are left t
o the discretion of the local education agency. It is recommende
d that districts develop policy guidance and procedures.
Source: Adapted from ERICDigest E537, Henderson, K. (1995).
Individuals with Disabilities Education Act (IDEA)
The culmination of many years of struggle on behalf of children
with disabilities occurred on November 29, 1975, when Preside
nt Ford signed Public Law 94–
142, the Education for All Handicapped Children Act (EHA). T
his landmark federal legislation mandated a free and appropriate
education for students with disabilities aged 3 to 21. The EHA
has been called the “first compulsory special education law,” an
d much of what happens in special education today is a direct re
sponse to the provisions embodied in it (Ysseldyke, Algozzine,
& Thurlow, 2000). Since first enacted, the EHA has been amend
ed to further emphasize the rights of individuals with disabilitie
s and their families. Today the EHA is known as the Individuals
with Disabilities Education Act (IDEA). Despite the name chan

ge and other amendments, the basic rights and provisions it affo
rded students with disabilities and their families have remained
largely the same: the right to free and appropriate education, the
right to due process, and the right to education in the least restr
ictive environment.
SPEEDBUMP—
If it wasn’t for this law, you probably would not be taking this c
ourse. IDEA changed the educational landscape in this country.
BOX 1.1
AMERICANS WITH DISABILITIES ACT
The year 2000 represented a milestone for the nation’s disabilit
y community; July 26 marked the 10th anniversary of the Ameri
cans with Disabilities Act (ADA). The ADA guarantees access,
accommodation, and removal of barriers to help people with dis
abilities fully participate in society. For people with disabilities
, the ADA is analogous to the Civil Rights Act of 1964. This la
w provided individuals with disabilities a declaration of liberty
from the days when they had little hope of competing on a level
playing field with their peers without disabilities. It provides th
e foundation of nondiscrimination against people with disabiliti
es in the areas of employment, state and local governments, pub
lic accommodations, and telecommunications.Free and Appropri
ate Education.
By law, school personnel must prepare an individualized educati
on program (IEP) for every student receiving special education
services. The IEP must include certain information about the chi
ld and the educational program designed to meet his or her uniq
ue needs. The IEP documents that a student is receiving an “app
ropriate education. In a nutshell, this information is (U.S. Depar
tment of Education, 2000a):
■ Current performance. The IEP must state how the child curren
tly is doing in school (known as present levels of educational pe
rformance). This information usually comes from the evaluation
results such as classroom tests and assignments, individual test
s given to decide eligibility for services or during reevaluation,
and observations made by parents, teachers, and related service

providers. The statement about “current performance” includes
how the child’s disability affects his or her involvement and pro
gress in general education.
■ Annual goals. These are goals that the child can reasonably ac
complish in a year. Goals may be academic, address social or be
havioral needs, relate to physical needs, or address other educati
onal needs. The goals must be measurable; meaning that it must
be possible to measure whether the student has achieved the goa
ls.
■ Special education and related services. The IEP must list the s
pecial education and related services to be provided to the child
or on behalf of the child. This includes supplementary aids and
services that the child needs. It also includes modifications (cha
nges) to the program or supports for school personnel—
such as training or professional development—
that will be provided to assist the child.
■ Participation with students without disabilities. The IEP must
explain the extent (if any) to which the child will not participate
with children without disabilities in the general class and other
school activities.
■ Participation in state and districtwide tests. Local educational
agencies must measure student progress with state-
or districtwide assessments used for students without disabilitie
s.
■ Dates and places. The IEP must state when services will begin
, how often they will be provided, where they will be provided,
and how long they will last.
■ Transition service needs. Beginning when the child is age 16 (
or younger, if appropriate), the IEP must state what transition se
rvices are needed to help the child prepare for leaving school.
■ Discipline. When disciplining students with disabilities, a sch
ool must determine if the behavior was a result of the disability
before taking action.
SPEEDBUMP—
The amount of paperwork and time it takes to develop an IEP is
a serious concern for school principals and educators.

Due Process. By law, students with disabilities and their famili
es are guaranteed rights of due process (see Figure 1.1). This m
eans that these students and their families have the same Fourte
enth Amendment rights enjoyed by all citizens. School personne
l cannot change the educational placement of students with disa
bilities without the informed consent (i.e., written permission) o
f the students’ parents or guardians. Parents also are entitled to
independent assessments and impartial hearings when decisions
about their children are being made. If needed, states must provi
de mediation services to resolve disputes with families regardin
g special education services.
Least Restrictive Environment. Students with disabilities must
be educated in the least restrictive environment. This means that
students with disabilities should be educated to the maximum e
xtent feasible with students without disabilities. Students with d
isabilities receive special education in a variety of settings. Som
e are enrolled full time in general education classes and receive
only indirect services from special education personnel. Some st
udents with mild disabilities are pulled out of their general educ
ation classes daily to go to resource rooms for special education
services. Still others are enrolled in self-
contained special education classes but, to the maximum extent
possible, attend general education classes for part of the school
day for certain kinds of instruction. For example, a student mig
ht be enrolled in a special class but attend a general education c
lass for instruction in math, music, art, or physical education. Fi
gure 1.2 lists key provisions of IDEA. In addition to IDEA, othe
r significant federal legislation promotes the rights and services
for individuals with disabilities. The mandate for a free, approp
riate public education for adults with disabilities also is parallel
ed in the Vocational Rehabilitation Act of 1973 (P.L. 93–
112). Section 504 of this act made it illegal for institutions or or
ganizations that receive federal funds to discriminate against cit
izens with disabilities.
FIGURE 1.1 Due Process Procedures

Source:Georgia Department of Education, 1989.
FIGURE 1.2 Major Provisions of IDEA
IDEA. In 1990, Congress amended the EHA in several significa
nt ways. The Individuals with Disabilities Education Act (IDEA
) (Public Law 101–
476) replaced the original title of the law. The name change refl
ects the need to emphasize the person first and the disability sec
ond. Also, individuals who receive special education up to age 2
1 should not be referred to as “children” as in the original title:
Education of Handicapped Children Act. Amendments in IDEA i
ncluded an expansion of related services such as therapeutic rec
reation, social work services, and rehabilitation counseling. Tra
nsition services were mandated to be written into IEPs. Transiti
on services begin at age 16. These services coordinate rehabilita
tive services—
for example, supported employment and independent living—
beyond the school years. The purchase or leasing of customized
equipment to support educational services (e.g., computers, whe
elchairs, adaptive equipment) also is authorized by this federal l
aw. The Individuals with Disabilities Education Act adds studen
ts with autism and traumatic brain injury to the list of populatio
ns provided special education.Americans with Disabilities Act
In 1990 Congress passed the Americans with Disabilities Act (A
DA). This national law provides individuals of all ages with pro
tection from discrimination due to a disability. The ADA is swe
eping in authority. Sometimes referred to as “the civil rights act
for the disabled,” ADA applies to a variety of venues including
public services, transportation, private sector employment, publ
ic accommodations, and communications. ADA requires that eve
ry sort of public accommodation from automatic bank machines
to football bleachers be accessible to individuals with disabilitie
s.
SPEEDBUMP—
The next time you go to a restaurant or sporting event see how
many accommodations you can identify.No Child Left Behind A

ct
On January 8, 2002, President George W. Bush signed into law t
he No Child Left Behind (NCLB) Act. This reauthorization of th
e Elementary and Secondary Education Act set challenging new
academic standards for the education of this country’s youth. Th
e Act is based on four education reform principles:
1. Stronger school accountability is needed for student improve
d learning.
2. Local schools need increased flexibility in order to respond t
o specific student needs.
3. Expanded options should be made available to parents.
4. Teaching methods should have a strong positive research basi
s. (www.nclb.gov)
Throughout the 670-
page document a central theme is repeated: Schools and teacher
s are accountable for the academic achievement of all students i
ncluding those who receive special education services. Some hi
ghlights of NCLB in relationship to special education students a
re:
1. Students with disabilities must be included in each state’s ne
w accountability system.
2. State plans must be coordinated with the Individuals with Dis
abilities Education Act.
3. Academic standards apply to all students including those with
disabilities.
4. Special education students must meet each state’s proficient l
evel of academic achievement by 2014.
5. States must report graduation rates for students with disabiliti
es and at least one other academic indicator.
In December of 2004, President George W. Bush signed the reau
thorized IDEA into law. The provisions of the act became effect
ive on July 1, 2005, with the exception of some of the elements
pertaining to the definition of a “highly qualified teacher” that t
ook effect upon the signing of the act. The final regulations wer
e published on August 14, 2006, and required the alignment of I
DEA and the NCLB (U.S. Department of Education, 2007a). Fro

m early beginnings in isolation and discrimination, individuals
with disabilities have taken their rightful place in the mainstrea
m of the U.S. education system.
SPEEDBUMP—
A child comes home from his first day of school. His mother as
ks, “Well, what did you learn today?” The kid replies, “Not eno
ugh. They want me to come back tomorrow.”
At-
Risk Students. By now it should be clear that legal mandates to
educate and provide services to individuals with disabilities ha
ve been the driving force to provide equal opportunities for all s
chool-
aged children. The IDEA is being reviewed continually in state
and federal courts. For example, overrepresentation of African
American students in special classes and the use of IQ tests to i
dentify African Americans and Hispanics as mildly “retarded” h
ave been scrutinized by federal courts. Such key provisions as “
appropriate education” and “nondiscriminatory assessment” also
have spurred important judicial decisions. Table 1.2 lists some
court cases that have shaped refinements of special education se
rvices to students with mild disabilities.
TABLE 1.2 Selected Judicial Decisions Since Passage of Public
Law 94–142 Focus on Students with Mild Disabilities
1975
Issac Lora et al. v. The Board of Education of New York et al.
Nondiscriminatory assessment procedures must be used when pl
acing minority students with emotional problems in special educ
ation programs.
1976
Frederich L. v. Thomas (Philadelphia). Class action suit that rea
ffirmed the right of students with learning disabilities to have a
ppropriate education programs.
1979
Larry P. v. Riles (California). Intelligence tests banned in Calif
ornia when assessing African American students as mildly retar
ded. Disproportionate numbers of African American students we

re placed in special classes for the mildly retarded.
1981
Luke S. and Hans S. v. Nixe et al. (Louisiana). Prereferral inter
ventions, curriculum-
based assessment, and direct classroom interventions were mand
ated for students with mild disabilities.
1982
Board of Education of the Henrick Hudson School System v. Ro
wley. This Supreme Court decision clarified “appropriate” educ
ation by determining that the intent of P.L. 94–
142 is to open the doors of public schools to students with disab
ilities, not to provide opportunities for students to reach maxim
um potential. Due process procedures to determine an appropria
te education were reaffirmed by the Court.
1984
Smith v. Robinson. This Supreme Court decision restricted the a
bility of students and their families to recover legal fees incurre
d in due process hearings. This decision was negated in 1986 wh
en Congress passed the Handicapped Children’s Protection Act,
which restored the courts’ authority to award legal fees to paren
ts who succeed in lawsuits or administrative hearings.
1984
Marshall et al. v. Georgia. Judge Edenfiel ruled that the overrep
resentation of African Americans in special classes was not disc
riminatory. In his view, lower socioeconomic conditions rather t
han discriminatory assessment and placement practices was the
reason African American students were placed in programs for t
he mildly mentally retarded. This was the first court case that hi
ghlighted the need to include a measure of adaptive behavior wi
thin the classroom as part of the criteria for determining mild in
tellectual disability.
1985
Burlington v. Department of Education, Massachusetts. The Sup
reme Court found that parents had the right to public school rei
mbursement of private school tuition if the public school progra
m rejected by parents was inappropriate.

1988
Honig v. Doe. The Supreme Court decreed that school systems
may not unilaterally exclude children with disabilities from the
classroom for dangerous or disruptive behavior. Any programma
tic changes because of behavior disturbances must follow due pr
ocess procedures outlined in P.L. 94–
142. In drastic situations the school can suspend a student for u
p to 10 days.
1989
Daniel R. R. v. State Board of Education. District and appeals c
ourts upheld the hearing officer’s decision that general educatio
n curriculum was beyond abilities of a student with retardation
and that he would receive little benefit from mainstreaming. Th
e courts found that for some children placement in general educ
ation environment would not provide a free appropriate educatio
n.
1990
Moore v. District of Columbia. Reversing an earlier decision, th
e federal appeals court ruled that prevailing parents were entitle
d to recover attorney fees when a final resolution of their specia
l education dispute came at the administrative hearing level.
1993
Zobrest v. Catalina Foothills School District. The court held tha
t provision of a sign language interpreter in a parochial school
was not an entitlement under IDEA; the decision was reversed i
n a finding that services of an interpreter were part of a general
government program that distributed benefits to any child qualif
ying for services regardless of the school the student attended.
1997
K.R. v. Anderson Community School Corp. The Seventh Circuit
court decided that a student with severe disabilities was not ent
itled to a publicly funded personal assistant while attending a pa
rochial school. The ruling set forth that under the IDEA, student
s with disabilities who choose to attend religious school need no
t receive the full range of services they would receive if they att
ended public school, but they must receive some services.

1999
Cedar Rapids Community School District v. Garret F. During th
e school day, Garret required services of a specially trained nurs
e because of his health needs. The school district, believing that
they were not obligated under IDEA to provide continuous nurs
ing care, refused to provide the services. The Supreme Court hel
d that the school district had to pay for the nursing services req
uired by Garret when he was at school.
2003
Lewisville Independent School District v. Charles W. and Gay
W. ex rel. Charles W. The Fifth U.S. Circuit Court of Appeals d
etermined that an intellectually superior 7th grader with pervasi
ve developmental disorder received FAPE, despite the parents’
belief that the child could make better grades and should attend
a private school for children with disabilities. The court determi
ned that his IEP was individualized, addressed all his special ne
eds, and resulted in both academic and nonacademic progress.
2004
C.J. v. Indian River County School Board. The court agreed wit
h the hearing officer’s determination that a student presenting w
ith bipolar disorder and oppositional defiance disorder was not e
ligible for special education because there was no support for a
finding of emotional disturbance. Although the student exhibite
d behavior and feelings that were inappropriate under normal cir
cumstances, the behaviors were intermittent in the school settin
g. The student’s behavioral problems, suspensions, and hospitali
zations did not interfere with her learning and she performed we
ll, above average in most of her classes. Unilateral placement in
a residential facility was largely for noneducational reasons.
Unreported in the special education data are at-
risk students who may or may not have received some type of co
mpensatory education. At risk is the phrase used for students wh
o fall through the cracks between special education and general
education. Unless a student is found eligible under IDEA for lea
rning disabilities, emotional disorders, or intellectual disability
(or other exceptionality listed in IDEA), the youngster is not re

quired to have an individualized educational program. Additiona
lly, the disability must interfere with school progress. The 2004
reauthorization of IDEA allows schools to use up to 15 percent
of special education funds for underperforming students in gene
ral education classrooms.
SPEEDBUMP—
In IDEA, the term mental retardation is used; throughout this te
xt we use the term “intellectual disability.” The explanation is i
n Chapter 3. In the meantime can you figure out why the authors
prefer intellectual disability rather than mental retardation?
Several categories of children with disabilities are at risk. Even
though they have a condition or a documented disability, they m
ay not be eligible for special education as defined in IDEA. For
instance, a child with an emotional disorder may not meet the fe
deral criteria for “intensity and degree,” or, despite an emotiona
l problem, a student might be making adequate grades.
Many students are protected under Section 504 of the Rehabilita
tion Act and the Americans with Disabilities Act (ADA). Howev
er, they are not covered by the stringent procedural safeguards a
vailable under IDEA. The safeguards include the right to remain
in the current placement, nondiscriminatory evaluation, an indi
vidualized educational plan, an impartial determination as to the
appropriate placement, and other due process protections (Roth
stein, 1995).
Youth with social maladjustments (e.g., incarcerated youth) do
not qualify for special education under IDEA unless a disability
is documented. There is disagreement over whether to identify
or even attempt to separate youth with social maladjustments fr
om other youth who meet the federal definition of emotional dis
turbance.
ADHD. Another category of children who require significant as
sistance in schools, but for whom there is no category in special
education, are those with attention deficit/hyperactivity disorde
rs (ADHD). In order to assess public opinion about whether AD
HD should be a separate special education disability, the 1990 a
mendments to IDEA required that the U.S. Department of Educa

tion solicit comments about the issue. It was decided that this c
ondition would not become a separate disability category under
IDEA. Several reasons were given, including the fact that many
youngsters with ADHD qualify for special education services as
learning disabled. Some youngsters with ADHD receive special
education services under the category “other health impairment
s.”
Youth who are addicted to drugs and alcohol are protected unde
r IDEA only if they qualify for special education and related ser
vices under one of the disability categories.
These students, like other categories described, are at risk, and
although they do not qualify for special education under IDEA,
they are entitled to protection under Section 504 of the Rehabili
tation Act or the ADA.
What determines whether a person is entitled to protection unde
r Section 504? The individual must meet the definition of a pers
on with a disability, which is
any person who (i) has a physical or mental impairment which s
ubstantially limits one or more of such person’s major life activ
ities, (ii) has a record of such an impairment, or (iii) is regarded
as having such an impairment.
If the person meets the definition of a person with a disability u
nder Section 504, “reasonable accommodations” must be made b
y recipients of federal financial assistance. Public school system
s receive this assistance, so teachers must make accommodation
s that are educationally beneficial for these students. The usual
remedy when a violation of Section 504 is proved is the termina
tion of federal assistance, which means loss of federal funding t
o the school system.
WHO RECEIVES SPECIAL EDUCATION?
In the United States, school-
aged children with disabilities are entitled to a free, appropriate
public education. It is illegal to discriminate against individual
s with disabilities. An individual cannot be denied an education
or a job because of a disability. Special education is mandated t

o provide services to students who have been identified as unabl
e to progress effectively in the general classroom as a result of t
hat disability. It is important to note that the presence of a disab
ility alone is not sufficient reason to initiate special education s
ervices. Special education is warranted only after all attempts to
help a youngster within the confines of the general classroom h
ave proved ineffective.
In the first textbook dealing with the “education of exceptional
children,” Horn (1924) observed that mental, temperamental, an
d physical differences were the bases for some students needing
special education. Today, many states organize their special ed
ucation departments along similar categorical lines. A category
is a descriptor or label assigned to a group of students. Althoug
h the names of the categories vary slightly from state to state, s
pecial education is generally provided for children within each
of the following categories:
1. Students with visual impairments or blindness
2. Students with hearing impairments or deafness
3. Students with deafness and blindness
4. Students with orthopedic impairments
5. Students with multiple disabilities
6. Students with language or speech impairments
7. Students with learning disabilities
8. Students with emotional disturbances
9. Students with mental retardation
10. Students with autism
11. Students with traumatic brain injury
12. Students with developmental delay
13. Students with health impairmentsPhysical/Sensory Disabiliti
es
Special learning needs in areas of physical abilities (e.g., seeing
, hearing, moving) are the basis for several categories of student
s with special needs. Most of us take normal vision and hearing
for granted. The expression “20/20 vision” is used to describe n
ormal visual functioning. Vision is measured by having people r
ead letters or discriminate objects at a distance of 20 feet. The t

ask is not difficult for most people. There are people, however,
who must stand closer to see what others see easily from 20 feet
away. These differences in visual functioning are the basis of d
eciding whether a student is blind or visually impaired. There ar
e also people who even at a louder volume cannot hear what can
easily be heard by the majority. Between normal hearing and de
afness are various degrees of hearing loss, and it is these differe
nces in degrees of hearing that are the basis for another categor
y of exceptional students (i.e., deaf or hearing impaired).
How different does vision or hearing have to be before a person
is considered blind or deaf? A person who, even with correction
(e.g., glasses), must be 20 feet from a target that a person with
normal vision can see at 200 feet or more is considered blind. P
eople with corrected vision better than 20/200 but not better tha
n 20/70 are considered visually impaired. Ability to hear is mea
sured along two scales: intensity and frequency. Intensity or lou
dness is measured in decibels (dB), and frequency or pitch is me
asured in hertz (cycles per second). Moores (1982) defines deaf
and hard of hearing in terms of the effects on hearing loss:
A deaf person is one whose hearing is disabled to an extent (usu
ally 70 dB or greater) that precludes the understanding of speec
h through the ear alone, without or with the use of a hearing aid
. A hard of hearing person is one whose hearing is disabled to a
n extent (usually 35–
69 dB) that makes difficult, but does not preclude, the understan
ding of speech through the ear alone, without or with a hearing
aid. (p. 17)
For practical purposes, deafness means the absence of hearing i
n both ears; people with deafness have great difficulty hearing c
onversational speech without the assistance of a hearing aid. Pe
ople with hearing impairments experience significant difficulty
in hearing.
There are other disabling conditions that are of a physical natur
e. For example, arthritis is a measurable inflammation of a joint
that limits movement. Cerebral palsy is impaired motor functio
n due to brain damage; it produces difficulties in motor control

that are observable in movement of large and small muscle grou
ps. Seizure disorder (i.e., epilepsy) is also a brain disorder that
results in convulsive episodes and periods of unconsciousness.
Other health impairments include severe orthopedic problems th
at adversely affect educational performance and limit strength,
vitality, or alertness. Special education may be provided to peop
le with physical differences caused by congenital anomalies (e.g
., spina bifida) as well as other general health and physical prob
lems (e.g., heart disease, asthma, diabetes, traumatic brain injur
y, autism).Intellectual Disabilities
Differences in intellectual performance or mental abilities are th
e bases for identifying a special need. To be considered intellect
ually disabled, an individual must demonstrate sub-
average intellectual functioning and delayed social development
. Intelligence tests frequently are used to determine if an individ
ual’s intellectual performance is below that of peers. Students w
ith scores from 50 to 75 on an intelligence test fall within the m
ild range of intellectual disability. Students with more complex
forms of intellectual disability are categorized as mildly, moder
ately, severely, or profoundly disabled. Besides the differences i
n severity linked to IQ scores, students with moderate to profou
nd intellectual disability usually have communication and health
problems. We refer to these students as having a developmental
disability because they have serious physical and medical comp
lications that are identified by a physician at birth or soon after
wards.
Students with intellectual disabilities demonstrate deficits in ad
aptive behavior (i.e., social development). Adaptive behavior ge
nerally refers to the way in which an individual functions in his
or her community. As with intelligence tests, adaptive behavior
evaluations are based on age-
group comparisons. Formalized inventories of functional abilitie
s (such as dressing oneself, using the telephone, or independentl
y moving about the neighborhood) help educational evaluators d
etermine adaptive behavior. Any determination of intellectual di
sability must include a measure of intelligence and a measure of

adaptive behavior skills.
Just as there are students with low intelligence test scores, there
also are students whose intellectual performance is above that o
f their classmates. Historically, giftedness was determined by hi
gh IQ test scores. This approach is no longer favored by many e
ducators because intelligence tests sample too narrow a range of
abilities. Creativity, musical talent, leadership skills, and probl
em-
solving abilities are a sample of talents not measurable through
intelligence testing. More recently, experts in the field of gifted
ness recommend a multidimensional approach to establishing cri
teria for identification of students with special gifts or talents.
According to Renzulli, Reis, and Smith (1981), in order to be id
entified as gifted, students should demonstrate:
1. High ability including measured intelligence evaluation
2. Creativity in the development and implementation of innovati
ve ideas
3. High task commitment—perseverance or diligence
Students with special talents are not viewed as needing special e
ducation services; consequently, they do not receive federally m
andated special education.HIGHLIGHT 1.2
Evan is a 14-year-
old resident of a Catholic residential facility for youngsters who
require child care in Syracuse, New York. Tall and athletic, Ev
an is a leader among the other boys. Mark Costello, a first-
year child care worker, describes his response to Evan’s invitati
on to come see the puzzle he has just completed.
As Evan led me over to a card table sitting in the middle of the l
iving room, it was obvious how proud he was of his accomplish
ment. Eager to lavish him with praise, I looked down at the tabl
e to see the three hundred jigsaw pieces carefully connected afte
r many evenings of effort. Pride quickly turned to confusion, ho
wever, when it became apparent that the picture was face down
on the card table.
“What picture, Mr. Cos?” Evan asked.
“Do you see the picture on the top of the box the pieces came in

, my friend?” I asked.
“Sure, what about it?”
“Well, that picture is now upside down on this card table and yo
u, old buddy, have just completed one heck of a tough task.”
While the other boys were trying to read Evan’s reaction to this
perplexing bit of news, I began to internalize my first real lesso
n about the significance of intellectual disability. Naïve but dete
rmined, he had stuck to a task few if any youths of normal intell
igence could tolerate. Was this just a glimpse of his true potenti
al? How hard it was that night to convince Evan of how proud w
e were of his somewhat tarnished accomplishment.
From Confessions of a Special Eddie: Reflections in Appreciati
on of Human Difference, p. 19, by T. Mark Costello, copyright
1994, New York: Wizard Press. Reprinted with permission.
SPEEDBUMP—
Do you think federal law should mandate special education prog
rams for gifted children?
Gifted programs exist in some school systems because of state o
r local leadership and funding. Four groups of students are unde
rrepresented in gifted education programs: culturally different, f
emale, disabled, and underachieving (Patton, Kauffman, Blackb
ourn, & Brown, 1991).
How different do measures of intelligence have to be before an i
ndividual is considered intellectually disabled or gifted? Differe
nces in scores on intelligence tests and measures of adaptive be
havior are evaluated in the same way as differences in scores on
hearing, vision, or physical performance tests. Standards for no
rmal intelligence and adaptive behavior are set by testing large
groups of individuals. Professionals then set criteria for intellec
tual disability or giftedness that are based on mean intelligence
scores and adaptive behavior ratings. For example, the common
standard for normal performance is a score of 90–
110 on an intelligence test; scores below 75 or above 130 are ge
nerally considered indicative of intellectual disability and gifted
ness. It is important to remember that special education services
for students identified as gifted are not mandated by federal leg

islation. Figure 1.3 traces the normal curve distribution of IQ sc
ores.
FIGURE 1.3 Normal Curve Distribution of IQ Scores
Academic Disabilities
With the categories of intellectual disability and gifted, it is ass
umed that the individual’s performance on achievement tests wil
l be consistent with the performance on intelligence tests. This
means that if a student obtains a high score on an intelligence te
st, high performance on an achievement test also is expected. If
students perform poorly on intelligence tests, it is expected that
their achievement test scores also will be low. There are student
s whose performance on achievement tests is not consistent with
their performance on intelligence tests. When the difference bet
ween ability (e.g., intelligence test performance) and achieveme
nt (e.g., reading, math) is significant, the student may be identif
ied as learning disabled. Students with learning disabilities com
prise one-half of the entire special education population.
SPEEDBUMP—
Why do you suppose so many students are identified as learning
disabled as compared to the other disability categories?
How different do scores on ability tests and scores on achievem
ent tests have to be before a student is classified as learning dis
abled? Although officials of the federal government have provid
ed guidelines for use in identifying students with learning disab
ilities, no specific criteria have been provided for judging when
discrepancies between ability and achievement are severe enoug
h to call a student learning disabled.
Students are considered eligible for special education if they me
et guidelines spelled out in state regulations. Due to a lack of co
nsistent criteria between and within states, it is likely that many
students in special education programs for students with learnin
g disabilities are misidentified.Communication Disabilities
Just as there are differences in the reading, writing, and mathem
atical skills of students, there are also differences in the ways st
udents speak and express themselves. Some people speak clearl
y, enunciating each part of their speech. Others speak quickly,

making it difficult for listeners to understand them. Some childr
en use speech as a means of making their desires, feelings, and
opinions known. Others are less adept at verbalizing personal ne
eds. There are accepted ages at which children are expected to d
emonstrate the use of various forms of communication. For exa
mple, most children understand approximately one thousand wor
ds, combine their words into simple sentences, and understand c
oncepts related to language (e.g., on, off, later) by the time they
are 2 years old. By the age of 7, children are expected to use cu
lturally acceptable grammar when speaking; language at this age
is much like that used by family and friends. Differences in lan
guage and communication skills are measured by performance o
n tests and classroom observations of student interaction. Differ
ences in language development and communication skills comm
only are observed in children of all ages. When these difference
s adversely affect educational performance, the individual may
be entitled to special services provided for students with langua
ge impairments.
How different does language have to be before a student is cons
idered language impaired? Many students in this category receiv
e special services for such problems as lisping, stuttering, and
mispronunciation of individual words (e.g., they say “wabbit” in
stead of “rabbit,” “pasketti” instead of “spaghetti,” or “bud” for
“bird”). Some of these students have voice tones that are too lo
w, too high, too nasal, too harsh, or too hoarse. There are no abs
olute standards for determining when an individual’s speech is “
too” nasal or “too” harsh or when it will adversely affect educat
ional performance. When speech mannerisms cause difficulties f
or the listener, a student may be referred for speech therapy. So
me teachers are more adept than others at understanding differe
nces in the language produced by their students. Similarly, the c
ontext in which speech occurs influences the judgments made ab
out it. Recent government figures indicate that there are more st
udents in this category than in any other besides learning disabil
ities. This is probably not surprising for a category based on dif
ferences in speech clarity or tone.Emotionally Disturbed

Just as standards for normal intellectual performance have evolv
ed within the educational system, standards for how students sh
ould act in school and society also have evolved. Standards for
normal behavior are based more on what is judged acceptable in
a specific setting than on judgments about how an individual pe
rforms on a test. Demonstrating intellectual performance that is
sufficiently above or below normal is the basis for being identif
ied as gifted or mentally retarded. Demonstrating unacceptable
behavior in school is the basis for being identified with behavio
r disorders or emotional disturbance.
Just how different does behavior have to be before a student is c
onsidered emotionally disturbed? Based on what you have learn
ed about the other conditions of special education, your answer
may be “behavior that is significantly different from the behavi
or of their peers.” You are right, but you will have trouble expla
ining behavioral differences. There are no numerical standards f
or normal behavior. There are no tests to measure the normality
of behavior. Classroom observations by teachers carry the most
weight in identifying students with emotional/behavior disorder
s. However, what is acceptable behavior for one classroom may
not be acceptable in another, and what is acceptable behavior fo
r one teacher is not necessarily acceptable for another.
Many students with emotional problems sit undetected in genera
l education classrooms. Although 1 percent of students receive s
pecial education services because of emotional disturbance, men
tal health experts estimate that from 6 to 10 percent of the scho
ol-
aged population have an emotional problem serious enough to w
arrant mental health care. Chief among these emotional problem
s are depression, posttraumatic stress disorder secondary to abus
e and attention deficit disorder with hyperactivity (Forness, 200
1).
HOW MANY STUDENTS RECEIVE SPECIAL EDUCATION?
Since 1976, the U.S. Department of Education has maintained a
database on the number of children with disabilities served in sp

ecial education programs. In 1990, several of the disability cate
gory labels within IDEA were revised: learning disabled was ch
anged to specific learning disabilities, mentally retarded became
mental retardation, and hard-of-
hearing and deaf were combined to become hearing impairments
; in other revisions to the regulations, multihandicapped was ch
anged to multiple disabilities, and autism, traumatic brain injury
, and developmental delay were added as separate categories.
More than six million students aged 3 to 21 receive special educ
ation services in public school or private settings (Twenty-
seventh Annual Report to Congress). In thinking about the numb
er of students involved, consider that it is about the same as the
total full-
time undergraduate enrollment in all U.S. colleges and universit
ies. The number of students who receive special education is mo
re than the combined population of North Dakota, South Dakota
, Montana, Nevada, Idaho, and Wyoming.
TABLE 1.3 Growth in Numbers of Students Ages 6 Through 21
Served Under IDEA
DISABILITY CATEGORY
1991–1992
2000–2001
2003–2004
Specific learning disability
2,247,004
2,887,217
2,866,908
Speech or language impairments
998,904
1,093,808
1,129,260
Mental retardation
553,262
612,978
582,663
Emotional disturbance

400,211
473,663
484,479
Multiple disabilities
98,408
122,559
132,645
Hearing impairments
60,727
70,767
72,048
Orthopedic impairments
51,389
73,057
68,234
Other health impairments
58,749
291,850
452,442
Visual impairments
24,083
25,975
25,879
Autism
5,415
78,749
141,002
Deaf-blindness
1,427
1,320
1,670
Traumatic brain injury
245
14,844
22,534
Developmental delay

28,935
66,267
All disabilities
4,499,824
5,775,722
6,046,031
Percent with specific learning disabilities, mental retardation, o
r emotional disturbance
71
69
65
Percent with specific learning disabilities, speech or language i
mpairments, intellectual disability, or emotional disturbance
93
88
84
Note: Reporting in the autism and traumatic brain injury categor
ies was optional in 1991–1992 and required beginning in 1992–
1993; developmental delay category is available only for childre
n under age 10. The table does not include students receiving sp
ecial education early intervention or preschool services.
There has been a steady increase in the number of students aged
6 to 21 receiving special education services. In 1992, 4,499,824
school-
aged students were placed in special education programs; in 200
3, the overall figure had increased to 6,046,031 students (see Ta
ble 1.3). Included in this figure are 269,596 children ages birth t
o 2 who received early intervention services and 680,142 childr
en aged 3 through 5 who received preschool services; the total n
umber of children benefitting from special education in 2000 wa
s 6,995,789 (U.S. Department of Education, 2007b). The numbe
r of students classified with specific learning disabilities, speec
h or language impairments, intellectual disability, and emotiona
l disturbance has decreased in recent years, while the number wi
th multiple disabilities, other health impairments (including AD

HD), and autism has increased. In 2003, for all racial/ethnic gro
ups, the largest disability category was specific learning disabili
ties (U.S. Department of Education, 2007b). Specific learning di
sabilities, speech or language impairments, intellectual disabilit
y, and other health impairments were among the five largest dis
ability categories for all racial/ethnic groups. Autism appeared i
n the top five disability categories only for the Asian/Pacific Isl
ander racial/ethnic group. The percentage of the population rece
iving special education and related services varies by race/ethni
city. In 2003, the percentage receiving special education (i.e., ri
sk index) was largest for American Indian/Alaska Native studen
ts (13.8 percent), followed by black (12.4 percent), white (8.7 p
ercent), Hispanic (8.2 percent), and Asian/Pacific Islander (4.5
percent) students. The average cost to educate a student with a d
isability is $12,639 per year (U.S. Department of Education, 20
02). Reasons for the increase in students identified as having sp
ecial needs include the following:
1. Poverty-related issues, such as inadequate health care
2. An increase in cultural and linguistic diversity in the schools
3. An increase in the numbers of students identified with specifi
c learning disabilities
4. The addition of new categories of students eligible for special
education
5. Variations in school referral and evaluation procedures
Special education’s growth has continued to increase the deman
d for special education teachers (U.S. Department of Education,
1999; 2007b).
The growth of special education services has caused other probl
ems. For example, school personnel have to decide how to pay f
or the increasing numbers of students. Because the cost of educa
ting students with special needs may come at the expense of edu
cating students in general education, school personnel face hard
choices when allocating funds. The growth of special education
is attributed directly to passage of the IDEA, which mandates a
“free and appropriate public education” for all students with di
sabilities.

For years many school districts organized their special educatio
n programs along categorical lines (e.g., emotionally disturbed,
learning disabled). Recently public schools have made a greater
effort to include students with disabilities in general education
classrooms. The “inclusion” movement is based on the premise t
hat students with disabilities will make greater progress if they
are allowed to learn alongside peers without disabilities. The 19
97 reauthorization of IDEA stated that special education student
s should be educated in general education classrooms to the max
imum appropriate extent. Inclusion efforts continue to show res
ults. During the 1984–
1985 school year, only 25 percent of students with disabilities a
ged 6–
21 spent more than 80 percent of their day in general education
classrooms. By 1998–
1999, almost half of all students with disabilities spent more tha
n 80 percent of their time in general education classrooms and t
his figure has remained constant for many years (U.S. Departme
nt of Education, 2001; 2007b). Unfortunately, the inclusion tren
d is not without problems. Forty-
two percent of general education teachers feel inclusion is “not
workable” due to deficiencies in teacher attitude, teacher prepar
ation, and administrative support (Henley, 2004).
SPEEDBUMP—
Because of the constant rise in the special education population,
the demand for teachers licensed in special education continues
to grow as well.
STUDENTS WITH MILD DISABILITIES
Many people experience mild vision, hearing, or other physical
problems but they are not typically among those receiving speci
al education services. Students with mild disabilities who do rec
eive special education are those typically included in the federal
categories of specific learning disabilities, intellectual disabilit
y, and emotional disturbance. Students with language or commu

nication impairments is another large category of mild disabiliti
es; however, because their difficulties are primarily treated by s
peech clinicians rather than teachers in general or special educat
ion classrooms, information about them is not included in this b
ook.
We do not use the term mild disabilities to imply that these stud
ents do not have serious learning problems or that their problem
s are less important than those of other students. We use this ter
m for these students because many of their characteristics overl
ap, many of the interventions used with them are effective with
all of them, and many of them can be educated effectively in ge
neral education classrooms with support rather than full-
time assistance from special education teachers. The three mild
disabilities are mild intellectual, learning disability, and emotio
nal disturbance.
Students classified with learning disabilities, mild intellectual d
isability, or emotional disturbance account for about than two-
thirds of all students with disabilities (U.S. Department of Educ
ation, 2007b), and they share many characteristics. For example
, students with learning disabilities often have problems with re
ading comprehension, language development, interpersonal relat
ions, and classroom behavioral control (Lerner, 2000). These sa
me characteristics are common in teacher descriptions of studen
ts receiving special education in the categories of mild intellect
ual disability and emotional disturbance.
If you think that these characteristics also can be found in stude
nts who do not receive special education services, you are corre
ct. It is a thin and sometimes arbitrary line that separates studen
ts with mild disabilities from other students. Many classroom pr
oblems are interactional: the result of a mismatch between teach
ing and learning style. The behavior, expectations, and attitude
of the general classroom teacher is a key component in determin
ing whether a student is referred and evaluated as having a mild
disability. For example, some characteristics of learning disabil
ities, such as dyslexia (i.e., an impairment in reading ability), ar
e neurologically based; other characteristics, such as distractibil

ity, can be based on teacher perception of student performance.
A student with dyslexia will be dyslexic in every classroom; on
the other hand, a student identified as distractible and hyperacti
ve in one teacher’s classroom may have less difficulty attending
in another classroom. How can this happen? Some teachers are
more adept at engaging students in their schoolwork than others
. In special education, never underestimate the power of good te
aching to “cure” a mild disability.
Whether it helps students with mild disabilities to be categorize
d is controversial. Over the years, each of the three subgroups o
f mild disabilities has been separated by distinct identification c
riteria, different teaching methods, teacher certificates linked to
a single disability, and different special education placements.
Each category is represented by separate professional organizati
ons and advocacy groups and their efforts influence the number
and types of services provided to students with disabilities. The
American Association for Individuals with Developmental Disa
bilities and the Council of Children with Behavior Disorders are
two examples of disability-
specific organizations. Researchers develop expertise within a s
ingle category of mild disabilities and report their findings in jo
urnals that specialize in intellectual disability, learning disabilit
ies, or emotional disturbance.
Still, students who are placed in different categories of mild dis
abilities share many common traits. Lack of interest in school a
nd low motivation are two traits displayed by many youngsters c
ategorized as having a mild disability. It also is clear that instru
ctional practices proved effective for students in one category o
f mild disabilities can be useful with students within another cat
egory. Such instructional strategies as peer tutoring, phonemic a
wareness, and cooperative learning can help students learn regar
dless of how their mild disability is categorized.
There are advantages and disadvantages to classifying students
by specific categories of mild disabilities. Special educators so
metimes use the term “labeling” to describe this categorization
process. Is it a good idea to label students? We will present the

facts about both sides of this issue. Ultimately you will need to
make your own professional decision about labeling students wi
th such terms as intellectual disability, learning disabilities, and
emotional disturbance. Whether to place a student into a mild d
isability category is an issue you will be faced with throughout
your career as a teacher.
Previous section
Next section
LABELING
Students identified as having problems in school either will mee
t eligibility criteria for special education services or will be uno
fficially labeled with such negative adjectives as “lazy,” “unmot
ivated,” “slow learner,” or “behavior problem.” In the latter cas
e, neither the teacher nor the student will get help. The student
will remain in general education and most likely continue to fail
in school. There is an increased probability that the student wil
l eventually drop out of school (see Figure 1.4).
FIGURE 1.4 Children with Disabilities Remain at Risk
Sources:U.S. Department of Education, 2004; U.S. Department
of Education, 2002.
In most states, a student is identified as requiring special educat
ion when school evaluation data match the student with a specif
ic disability category that is outlined by state education regulati
ons. This classification process assumes that assigning a student
a categorical name implies knowledge about the characteristics
of the student’s learning problem. This categorical approach to
providing help has been roundly criticized by many educators w
ho claim that labeling a student does more harm than good. Wha
t students are called determines what services they receive and
where they will receive them. Because this classification proces
s alters the school experience of many students, professionals h
ave researched and described the advantages and disadvantages
of the labeling associated with it.Advantages of Labeling

The advantages of labeling were more obvious in the formative
years of special education (mid-
1940s to early 1970s) than they are now. For instance, without t
he category of learning disabilities, advocates for these children
would have had no rallying point to promote educational progra
ms. Imagine how ineffective scientists would be in raising mone
y for cancer research if they had no name for it. The advantages
of labeling can be summarized as follows:
1. Federal and local funding of special education programs are b
ased on categories of disabilities.
2. Labeling enables professionals to communicate with one anot
her because each categorical label conveys a general idea about
learning characteristics.
3. The human mind requires “mental hooks” to think about prob
lems. If present categorical labels were abolished, a new set of
descriptors would evolve to take their place. There is ample evi
dence of this in the evolution of the term “mildly retarded.”
4. Labeling the disability spotlights the problem for the public.
Labeling can spark social concern and aid advocacy efforts.
5. Labeling may make the majority without disabilities more tol
erant of the minority with disabilities. In other words, the action
s of a child identified as having intellectual disability might be t
olerated, whereas the behavior of a peer without intellectual dis
ability would be criticized.
6. Labeling has led to the development of specialized teaching
methods, assessment approaches, and behavioral interventions t
hat are useful for teachers of all students. (Hallahan & Kauffma
n, 1982)
DISADVANTAGES OF LABELING
Because of IDEA, students with disabilities have made significa
nt gains in public schools. These advances have been accompani
ed by problems inherent in officially designating someone abnor
mal. Make no mistake about it; these labels stick. Once a child i
s categorized with intellectual disability, emotional disturbance,
or learning disabilities, that information will be forwarded to e

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