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Larry P. v. Riles:
Overrepresentation & Bias in
   Mental Measurement




    Sherwood Best, Ph.D.
         Professor
    ...
Larry P.
          v.
     Wilson Riles

495 F. Supp. 926 (1979)

Argued October 11, 1977
Decided October 16, 1979
       ...
Terms
 EMR – Educably Mentally Retarded. A term
  used by school districts to assign students
  with IQ scores in the bor...
Terms
 Preliminary injunction – An injunction
 is a court order that requires a
 person or entity to do something or
 ref...
Background
 Larry P. attended school in the San
 Francisco Unified School District &
 was experiencing academic difficult...
Background
 Placement into EMR classes began with
  referral from general education, followed by
  assessment & recommend...
Background
 A class action lawsuit was brought on behalf
  of 5 African-American children challenging the
  use of certai...
Background
 The district court granted a preliminary
  injunction. The defendants appealed & the
  appellate court affirm...
Background voluntarily
 In January 1975 the defendants
  placed a moratorium on all IQ testing for
  EMR placements of Af...
Issues
 Were the standardized intelligence (IQ) tests
  used in California at that time validated for
  the specific purp...
Applicable Law
 The Education of All Handicapped
  Children Act (EAHCA) of 1975
 The Rehabilitation Act of 1973
 Title ...
Arguments - Plaintiffs
 The IQ tests were biased & the
 defendants discriminated against
 African-American children by us...
Arguments - Defendants
 Statutory requirements approved intelligence
  testing for EMR placement.

 IQ tests were not un...
Holding
 IQ tests were used to place African-American
  students into EMR classes.

 IQ tests were not validated for the...
Holding
 Violation of Equal Protection Clause of U.S.
  Constitution was not established for Wilson
  Riles because he wa...
Dicta
 EMR curriculum was not designed to help
  children learn the necessary skills to return to
  general education.

...
Court’s Orders
 California school districts were enjoined from
  using IQ tests for identification & placement of
  Afric...
Implications - Special Education
 Increased attention & compliance with
  statutes & regulations (EAHCA non-
  discrimina...
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Larry p. v. riles 1979

  1. 1. Larry P. v. Riles: Overrepresentation & Bias in Mental Measurement Sherwood Best, Ph.D. Professor CSULA 1
  2. 2. Larry P. v. Wilson Riles 495 F. Supp. 926 (1979) Argued October 11, 1977 Decided October 16, 1979 2
  3. 3. Terms  EMR – Educably Mentally Retarded. A term used by school districts to assign students with IQ scores in the borderland-mild range to special classes. Not a federal category.  Test Validity – A statistical term that is applied to a standardized test to evaluate whether that test measures what it purports to measure (intelligence, for example) 3
  4. 4. Terms  Preliminary injunction – An injunction is a court order that requires a person or entity to do something or refrain from taking a particular action.  Moot – Beside the point. 4
  5. 5. Background  Larry P. attended school in the San Francisco Unified School District & was experiencing academic difficulty in his classes. As per the district policy at that time, he was assessed by a school psychologist using the Stanford Binet Intelligence Test. The results of this test indicated that Larry P. had mild mental retardation & he was subsequently placed in an EMR class. 5
  6. 6. Background  Placement into EMR classes began with referral from general education, followed by assessment & recommendation by a school psychologist.  California’s EMR classes of the 1970’s were designed to teach social & functional skills, with little alignment with academic curricula.  A disproportionate number of African- American and Latino students were placed in EMR classes. 6
  7. 7. Background  A class action lawsuit was brought on behalf of 5 African-American children challenging the use of certain IQ tests to place students into EMR classes. The complaint was filed in federal district court against:  San Francisco Unified School District  State Superintendent Wilson Riles  Members of the California State Board of Education  Members of the San Francisco City Board of Education 7
  8. 8. Background  The district court granted a preliminary injunction. The defendants appealed & the appellate court affirmed the district court.  In August 1973 the defendants requested a 3- judge court to determine if IQ tests were racially & culturally biased. The district court rejected this request.  In December 1974 the court expanded the original injunction to include all African- American children in MR classes who were there based on IQ test results. 8
  9. 9. Background voluntarily  In January 1975 the defendants placed a moratorium on all IQ testing for EMR placements of African-American children.  In July 1977 the plaintiffs filed an amended complaint alleging a series of legal violations. The trial began October 1977 and concluded March 1978.  Wilson Riles filed an appeal to the Ninth Circuit. The Chief Judge was Robert F. Peckham.(appellate court judge for expanded class) 9
  10. 10. Issues  Were the standardized intelligence (IQ) tests used in California at that time validated for the specific purpose used?(looking at content)  Were African-American students being labeled as EMR inappropriately & disproportionately due to IQ testing?  If so, did their placement in EMR classes constitute discrimination?  If so, were African-American students being placed improperly and stigmatized by the IQ tests? 10
  11. 11. Applicable Law  The Education of All Handicapped Children Act (EAHCA) of 1975  The Rehabilitation Act of 1973  Title VI of the Civil Rights Act of 1964  The Equal Protection Clause of the 14th Amendment of the US Constitution  The Equal Protection Clause of the California Constitution 11
  12. 12. Arguments - Plaintiffs  The IQ tests were biased & the defendants discriminated against African-American children by using them.  The use of IQ tests resulted in disproportionate placement of African- American students into EMR classes that stigmatized them, provided inadequate education, & limited their skills.(Equal Protection Violation) 12
  13. 13. Arguments - Defendants  Statutory requirements approved intelligence testing for EMR placement.  IQ tests were not unduly relied upon & used to confirm suspicion.  Stated that predictive validity of IQ tests was generally known & accepted.  Higher incidence of mental retardation among African-Americans, attributed to:  Genetic factors  Societal/environmental factors 13
  14. 14. Holding  IQ tests were used to place African-American students into EMR classes.  IQ tests were not validated for the specific purpose used.  The use of the tests had discriminatory effect on African-American students.  Non-discriminatory assessment mandate of EAHCA was violated.  Civil Rights Act of 1964 & Rehabilitation Act of 1973 were violated as IQ tests were found to be discriminatory. 14
  15. 15. Holding  Violation of Equal Protection Clause of U.S. Constitution was not established for Wilson Riles because he was not in office when the IQ test policy was adopted.  Violation of Equal Protection Clauses of California State Constitution was moot as constitutional claims were not established. The appellees were not attacking the constitutionality of of the state statute but the actions of the state board in complying with the statute. 15
  16. 16. Dicta  EMR curriculum was not designed to help children learn the necessary skills to return to general education.  EMR classes were “dead end” & stigmatizing.  The IQ tests did not eliminate cultural bias, as previous revisions dealt with gender bias.  Alternative, less biased assessments were available.  Defendants’ position of genetic & socioeconomic deprivation were untenable. 16
  17. 17. Court’s Orders  California school districts were enjoined from using IQ tests for identification & placement of African-American children into special education classes.  The defendants had to monitor & eliminate disproportionate placement of African- American children into special education classes.  All African-American children in EMR classes at time of decision were to be re-assessed 17
  18. 18. Implications - Special Education  Increased attention & compliance with statutes & regulations (EAHCA non- discriminatory assessment practices).  Development of culture-fair assessment procedures.  Reinforced use of multiple assessments.  Reticence to place some children into special education may be a disservice.  Groups outside the class will challenge assessment with resulting policy changes. 18
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