Olivia Thomas
Professor Abbot
ED 492
11/25/2012
The court case of Board of Education in Sacramento, CA versus Holland happened in
1994 and regarded a least restrictive environment and its four factors including the needs of all
children in the school that were to be considered by FAPE. (NAU, 1999) In this case, the circuit
court found in favor of the Holland family.
The issue that caused this court case to arise was the fact that the Holland family wanted
their daughter, Rachel who was eleven years old at the time, in the regular classroom full time.
The school district in which Rachel attended school rejected her parents request to have her
fulltime in the regular classroom. While the school districts counter proposal sounded good, it
would have required Rachel to move classrooms six times a day. The counter proposal from the
school district wanted Rachel to be in a special education classroom for all academic classes, and
only in a regular classroom for subjects such as the arts, lunch, recess, etc. Because Rachel’s
parents did not want to agree to the terms, they sent Rachel to a private school who
would allow her to be in the regular classroom fulltime. (Kids Together, Inc, 1994)
While Rachel’s parents and the school district were able to agree on an
Individualized Lesson Plan (IEP), their dispute created a distraction which caused
Rachel’s IEP that was supposed to be reviewed annually to be forgotten. While things
continued to escalate between the school district and Rachel’s parents, the court case
also escalated into a state hearing, where the Holland’s had an argument that the
District did not make enough effort to educated Rachel according to IDEA standards.
The hearing officer found that, “1) Rachel had benefitted from her regular
kindergarten class, and that she was motivated to learn and learned by imitation and
modeling; 2) Rachel was not disruptive in the regular classroom and 3) the District
had overstated the cost of putting Rachel in regular education.” (Kids Together, Inc,
1994) Although the district counter appealed the Hollands, the court still ruled in their favor
One question in this case is whether academic or non-academic factors are more
important in determining whether Rachel should be in a regular classroom fulltime. Through the
information the official gave, it appears that Rachel received academic benefit in great amount,
as well as nonacademic. Rachel was able to learn in a classroom that suited her needs, and she
was able to do her best successfully. Rachel was also able to socialize with children her age
which promoted her learning through imitation and modeling. The nonacademic and academic
factors in this case worked hand in hand and enhanced each other.
Another question in the case was whether or not Rachel was disrupting in the regular
classroom. This question as answered by the official, saying that Rachel indeed was not
disrupting any of her fellow classmates, but instead was engaged in her learning and was
benefitting from being fulltime in the regular classroom.
A question that still lies is the question of whether or not the outcome would have been
the same if the district would have provided more evidence. The Hollands had an edge on the
case because they had the officer on their side whom provided extensive evidence that supported
Rachel’s cause and made the District look unprepared and inflexible. One of the main issues in
this case was the cost of putting Rachel in the regular classroom versus keeping her in special
education. The district was said to have grossly overestimated the cost of Rachel’s education,
saying that it would cost close to $200,000 annually. With this claim came no evidence, thus
leading the court to rule in favor of the Hollands. If the district was truthful about the cost of
educating Rachel, it is a question of ethics whether or not the school should provide her the most
appropriate education, or if they should urge her to seek an education elsewhere. Some people
believe that a large sum of money should not be spent on one student if it means that five other
students are not going to receive a free and appropriate education. This is a decision that is
ultimately decided upon by the court.
LRE has many continuums of special education service models, some that would most
likely cost school districts large amounts of money. Because of this, and because of the evidence
the officer provided, it is clear that in Rachel’s case, she would not be costing her school district
the large amounts of money that they were claiming, some $200,000. Rachel most likely will not
need to be educated in a living environment or in the hospital, and will not need to spend several
hours in special education, after spending a majority of her day in the regular classroom, giving
her a double dose of schooling each day. Rachel’s cause in my opinion let her school district off
easy, not costing them gross amounts of money and not creating issues within the regular
classroom for Rachel, her classmates, or her teachers.
Congress passed a law that all children must receive a regular education to the fullest
extent, “appropriate with related services and supplementary aides.” (Abbott, 2012) According to
the Least Restricting Environment, the regular classroom must be considered to be the least
restricting environment, but may be allowed accommodations from special education teachers
and other resources. (Abbott, 2012) The fact that Rachel was not disruptive in the regular
classroom when she was in it fulltime and the fact that she was learning from the other students
is back-up that when congress passed LRE laws, they made the right decisions.
Works Cited
Abbott, D. (2012). ED492-LRE. Indianapolis, IN, USA.
Kids Together, Inc. (1994, Jan 24). Sacramento v. Rachel H. Retrieved from Better Together:
http://www.kidstogether.org/right-ed_files/rachel.htm
NAU. (1999). Important Court Cases in Special Education. Retrieved from Methods and Materials in
Special Education: http://jan.ucc.nau.edu/~jde7/ese504/class/advanced/courtcases.html