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Kerry Bryan

EDUC 529
IDEA Project
IDEA: Focus on Least Restrictive Environment
The Individuals with Disabilities Education Act has many parts
that work together to protect those with disabilities, and their families.
One of the aspects of this act is least restrictive environment (LRE).
This is one of the most important and challenging aspects for me to
understand as a future special education teacher. As I work as a
paraprofessional in a mild-moderate special education classroom right
now, I see the mainstreaming taking place each day. It is indeed
difficult to determine what is best for a child. Therefore, the following
pieces of LRE seems especially relevant to be addressed including; its
legal implications, history and importance, court cases, and a general
overview of why the laws of LRE exist.
In 1975 LRE began in the IDEA and, although its basic principles
have stayed the same, it has also developed over time. Before the
matter of LRE, students must first qualify for special education and
have an Individualized Education Program (IEP) that outlines their
special needs and goals. Because a free, appropriate public education
must be available to all students, special education students are
protected. Now, to decide what is appropriate partially has to do
with environment and thus, the LRE. Although the LRE doesnt

specifically define the term inclusion, we have used this to go along

with LRE. Inclusion, like mainstreaming, is keeping special education
students inside the general education classroom as much as possible
and suitable.
When establishing the LRE for a student, one might wonder
about the effects of a special education student on general education
students in the classroom. Will that student receive more attention?
Will it distract the other learners? In order for the LRE to be
appropriate, he or she cannot be in a classroom and prohibiting other
children from learning. Inclusion for each student, even partially
cannot necessarily be demanded or expected. The law requires that all
considerations have been made for students to be receiving the best
possible education. It states students with disabilities are educated
with children who are not disabled removal of children with
disabilities from the regular educational environment occurs only when
the nature or severity of the disability of a child is such that education
in reglat classes cannot be achieved satisfactorily. (20 U.S.C. 1412(a)
(5)(A)) This means that the general education is the first choice, but if
that isnt possible, other measures must be taken. That leads to
special education or resource rooms and sometimes even special
schools. Extreme cases take students out of schools and require them
to be homebound or hospitalized. Although the law is clear, it is still

important to view each student as an individual and carefully review

his or her situation and then make an informed decision.
Many cases regarding LRE have been brought to court because it
is such a controversial and touchy issue. People are rightfully very
passionate about childrens education and will go to great lengths to
ensure that their students are provided what is best. In our text, Kurt
E. Hulett explains how often parents are advocating for their children to
be in the general education classroom and then says, However, it is
not uncommon for contemporary LRE cases to involve parents
advocating for students to be placed in segregated, private schools
(2009). It is fascinating how some parents are moving to various
extremes as they determine in their minds what is best for children.
One significant court cases on the topic of LRE is Roncker v.
Walter (1983), in which, the students parents believed their son should
spend more time in a general education classroom instead of a special
education school. The first court sided with the school, but the next
court agreed with the parents and overruled the original decision. As a
result, the Roncker portability test was born, which asks whether
proper services can be provided in an inclusion environment and if so,
that classroom would be the LRE. Although this is a broad guideline,
its a decent place to begin when determining the LRE for an individual.
Another central court case is Hartmann v. Loudoun County Board
of Education (1998). Matt Hartmann, an autistic 11-year-old was

originally placed in a general education class, with an aid, some time in

a special education classroom and lots of help with speech. Although
they had specific training for the staff of the school, Matt still exhibited
disruptive and aggressive behaviors. Because he did not seem to be
improving, the IEP team decided that he should be placed in a different
school. His parents disagreed, saying this violated his right to the LRE
and the district court supported them. However, the 4th Circuit
deemed that the first placement was not appropriate as it did not fit
the following criteria: there was not enough educational benefit, the
special school would provide more benefit than inclusion, and Matts
disruptive behaviors dont allow the other children to receive their
proper education. This court case shows us that even when schools
really try to accommodate students with special needs, sometimes it
truly isnt the best fit. However, more schools should show this much
effort when attempting to meet the needs of students, instead of
simply writing them off before theyve even had a chance.
After reviewing just a few of the court cases regarding LRE, it is
clear to see why there are so many. Determining the least restrictive
environment for students is a vital aspect of their education and it is to
be taken very seriously by all parties involved. Its important that
students have people who are advocating for their rights so the can be
in the setting that is most appropriate for them. LRE is not a simple
subject that can become perfected through research and experience.

Each new student brings new challenges when deciding how to provide
the most fitting situation for learning. We must continue to work
together to keep kids in the least restrictive environment and help
them to grow as individuals and learners.

Hulett, K. E. (2009). Legal aspects of special education. Upper Saddle
River, New Jersey: Pearson Education, Inc.
Wright, P. (2009, February 01). Least restrictive environment (LRE) and
FAPE. Retrieved from