This document discusses legal precedents for providing sheltered instruction and English language development to English learners. It outlines the dual obligations school districts have in law to both develop students' English proficiency through English language development, and provide meaningful access to academic content instruction through sheltered instruction. The document then defines sheltered instruction and English language development, explaining key differences and components of each. It emphasizes that both sheltered instruction and ELD are necessary to make content accessible to English learners and close persistent achievement gaps.