Pennsylvania Association for Retarded
Children (P.A.R.C.)
v.
Commonwealth of Pennsylvania
(1971, 1972)
Rachaellen M. Murr
MA School Psychology candidate
Ball State University
Overview/Purpose
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Brief Background
Court Case Details
Verdict
Effects on school psychologists
Implications for the field
Historical Background
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Right to a free public education
Children with mental “retardation” before 1970’s
School psychologists’ role
What were parents supposed to do?
P.A.R.C. v. Commonwealth of Pennsylvania
became a turning point in history
(Jacob, Decker, & Hartshorne, 2010; P.A.R.C., 1972)
Court Case Details
• Date: 1971-1972
• Plaintiff:
▫ P.A.R.C. including 13 parents of children
• Defendant:
▫ Commonwealth of Pennsylvania (State of
Pennsylvania’s State Education Board, specifically
pinpointing 13 school districts)
Jacob, Decker, and Hartshorne , 2010;
Court Case Details
• Basis:
▫ Protection Clause
▫ Procedural Due Process
• Plaintiff's Attorney
▫ Thomas K. Gilhool
(Gilhool, 2011; P.A.R.C., 1972)
Court Verdict/Ruling
• Consent Agreement reached in 1972
• Ruling favors plaintiff’s concerns
• Reasoning:
▫ All are capable of benefitting from education
▫ “self-sufficiency” and “self-care”
• Placement of all children into a “free program of
education and training appropriate to the child’s
capacity”
(Jacob, Decker, & Hartshonre, 2010; P.A.R.C., 1972)
Outcome
• Pennsylvania-first state to guarantee education
to such children
• Mills v. Board of Education of District of
Columbia and other cases
• Development of federal law leading to IDEA
(Jacob, Decker, & Hartshonre, 2010; P.A.R.C., 1972)
Implications to school Psychology
• How did it change practice today?
• Study by Sansosti and Sansosti (2013) Evidence
of evolution of practice with children with
impairments
(Sansosti & Sansosti, 2013)
Growth of Knowledge
• Change in general practices
• Struggle for access to fair education
• How does this knowledge allow a school
psychologist to develop professionally?
▫ Good practices to follow
References
Gilhool, T. K. (2011, September 28). Interview by L. Martin.
[Video recording] Visionary Vioces Interviews. Institute on
Disabilities. Retrieved from
http://disabilities.temple.edu/voices/detailVideo.asp?mediaC
ode=006-01#.UpyW_MRDuSp
Jacob, S., Decker, D., & Hartshorne, T. S. (2010). Law and
School Psychology: An Introduction 27-31. Ethics and Law
for School Psychologists 6th Edition. John Wiley and Sons.
Hoboken, New Jersey.
Jacob, S., Decker, D., & Hartshorne, T. S. (2010). Ethical-Legal
Issues in the Education of Students with Disabilities Under
IDEA 79-123. Ethics and Law for School Psychologists 6th
Edition. John Wiley and Sons. Hoboken, New Jersey.
Kuriloff, P., True, R., Kirp, D., & Buss, W. (1974). Legal Reform
and Educational Change: The Pennsylvania Case. Exceptional
Children, 41, 35-42.
References
Public Interest Law Center of Philadelphia. (2013) Pennsylvania
Association for Retarded Citizens (PARC) V. Commonwealth of
Pennsylvania. Retrieved from http://www.pilcop.org/pennsylvaniaassociation-for-retarded-citizens-parc-v-commonwealth-ofpennsylvania/
Sansosti, F. J., & Sansosti, J. M. (2013). EFFECTIVE SCHOOL-BASED
SERVICE DELIVERY FOR STUDENTS WITH AUTISM
SPECTRUM DISORDERS: WHERE WE ARE AND WHERE WE
NEED TO GO. Psychology In The Schools, 50, 229-244.
doi:10.1002/pits.21669
Shapp, M. J. (1972). Right to an Education for the Retarded in
Pennsylvania, The. Syracuse L. Rev., 23, 1085.
The Pennsylvania Association for Retarded Children v.
Commonwealth of Pennsylvania. 343 F. Supp. 279 (1972). Retrieved
from LexisNexis Academic database.
Yell, M. L., Rogers, D., Rogers, E. L. (1998). The Legal History of
Special Education: What a Long, Strange Trip It’s Been! Remedial
and Special Education: A journal of the Hammill Institute on
Disabilities, 19, 219-228. doi: 10.1177/074193259801900405