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Special Education: A twenty-four part series on advocacy

Equity Red Stop Sign with Wheel chair and two people

Equity Red Stop Sign with Wheel chair and two people


The following is a list of the articles in the advocacy series.

  1. FERPA and Special Education Advocacy: The Gordian Knot Published in the INCIID INsights Newletter January 15, 2015
  2. Organizing Educational Records: How to organize your records. Pulished in the INCIID Insights Newsletter on January 29, 2015
  3. Special Education Advocacy: Strategies Published in the INCIID Insights Newsletter on February, 12, 2015
  4. Special Education Unzipped: How to analyze and come to a conclusion. Published in the INCIID Insights Newsletter on February 26, 2015.
  5. Special Education ESY: It is time to ask for an extended school year! Published in the INCIID Insights Newsletter on March 12, 2015; Web Conference March 18, 2015
  6. Special Education Advocacy Styles: Adversarial or Aggressive  INCIID Insights Newsletter  Web Conference Registration for April 1, 2015
  7. Special Education: What you need to know about What you need to know or Do Not Be Afraid to Invite the Elephant into the Room, April 8, 2015. Listen to the recorded online Workshop - from April 22, 2015 7:30 - 8:30 PM ET
  8. Special Education: April 29, 2015 Newsletter  Meeting Preparation; What you need to know about what you need to know. Online workshop: Register for the May 6 Webinar
  9. Special Education: Webinar on Educational Jargon and How Not to Use It! - June 10, 2015: IEP's are like a box of chocolate. You never know what you're gonna get.
  10. Special Education: Register for the Webinar on Parental Rights July 1 at 7:30PM ET based on the article: Parental Rights and Participation

READ the American Academy of Pediatrics Clinical Report on IDEA

Sign up for the INCIID Insights Advocacy Newsletter  Don't forget to check the INCIID Calendar (under Community).

Ask an Advocate Forum where Brice Palmer will answer your questions.


Senator Jeff Sessions as Attorney General: What's WRONG with that IDEA?

Human Rights

By Nancy Hemenway

Human RightsSenator Jeff Sessions (Jefferson Beauregard “Jeff” Sessions III) is the new administration’s top pick to be the highest law enforcement officer in the land -the United States Attorney General. The Attorney General heads the US Department of Justice, which is charged not only with defending but also enforcing federal law, including the Individual Education for Disabilities [Improvement] Act (IDEA/IDEIA). Sessions hails from Alabama, a state that has yet to inact Autism insurance reforms. 
Although a potential appointment of Senator Sessions raises many concerns, the purposes of this article is to spotlight Senator Sessions’ previous remarks about special education in his official Senatorial capacity. 

Attorneys, advocates and parents of children with disabilities are on high alert as a result of based on remarks made by Senator Sessions in his May 2000 speech from the floor of the United States Senate.

On May 8, 2000 Senator Sessions gave a speech on the Senate floor. In his speech he opined, the need for reform of the IDEA. Senator Sessions, a former school teacher from decades gone by, calls the IDEA a “good goal” but he also said --

                                                              “We have created a complex system of federal regulations and laws that have created lawsuit after lawsuit, special treatment for certain children and that are a big factor in accelerating the decline in civility and discipline in classrooms all over America. I say that very sincerely.”

This statement by Senator Sessions shows an antiquated notion and degree of ignorance about the make-up of the student population in public schools.  Maligning the federal law and blaming the intended recipients of the strict procedural framework the rights and procedures is disingenuous and misplaced. Senator Sessions could have also discussed the well documented incompetency of some public school special education personnel from coast to coast. Failure in the classroom has little to do with the mandate to educate students with disabilities and more to do with failure of application of the law to meet the unique needs of students with disabilities.  

The IDEA guarantees students with disabilities a Free Appropriate Public Education (FAPE). (20 U.S.C § 1412 et sec)

 In his speech Senator Sessions directly blames the IDEA for the lack of control in the classroom.

                                    “We have children we cannot control because of this federal law.” 

That statement is preposterous. The lack of instructional control when trying to manage and teach children - and in particular children with disabilities - is attributable to a lack of understanding of the function of their behavior

Everything we as human beings think, do, or feel is behavior. All behaviors are ways to communicate. If one does not understand the function of a behavior there is almost no chance to change, or shape it to an acceptable or new appropriate behavior. Among many, there is a common misconception that inclusion is mainstreaming all students with disabilities into one classroom. Students who are mainstreamed need supports and sometimes adaptations to the curriculum. Without the appropriate supports, they fail, are punished, ostracized, and/or bullied. Special education under the IDEA mandates that school districts provide an education with services and supports that meet their unique educational needs.

Parents have good reason to be concerned for the welfare of their disabled children if Senator Sessions is appointed Attorney General of the United States. His May 8, 2000 speech on the Senate floor has, to my knowledge, not been rescinded or amended by Senator Sessions. Will Sessions support and defend IDEA or will he allow further degradation of a law designed to protect and educate children with disabilities?

Research shows us that children with disabilities are at a greater risk for restraint, seclusion and other abusive and aversive methods of discipline that perpetuate more unacceptable behaviors as unintended consequences of aversive actions and punishment by public schools.

Many of the letters and statements from educators that Senator Sessions discussed originate from teachers or school systems officials that are not evaluating and treating a student’s target behaviors appropriately with “best practice methods” to shape, change and teach appropriate new behaviors. Senator Sessions reaches his conclusions and opinions based not on statistics or data but “anecdotal stories” he received from constituents calling attention and giving him their perception of the problem.

In addition, Senator Sessions provided another anecdotal story line about a case in which two students were caught with weapons that the students said were accidentally left in their vehicles as a result of coming to school grounds from target shooting. One was expelled and never returned to school and the other was a special education student (disability not specified) who was assigned to an alternative school for 45 days before he returned to his school.  According to Senator Sessions,

                                “The second student’s handicap does not prevent him from knowing right from wrong.”

The point is not “right from wrong”. For example, his disability may not deter him from understanding right from wrong - but his executive function may if, for example, he has ADHD. In that situation the student could well have a diminished capacity to organize and also have a disturbance of his memory function. All of which could increase the likelihood that the student might forget his gun was in the car. In that analysis, the student would be punished as a result of his disability.  There is no way to know from this brief anecdotal story what the young man’s disability was. If the student’s executive function and memory issues are at issue his disability absolutely is important in determining how to proceed. Expulsion or other punishment based on an incapacity due to a disability is wrong, illegal and not very productive.

When a behavior of such magnitude occurs and expulsion is an issue, the IDEA mandates that students with a disability have a manifestation hearing to determine if the behavior was a result of the student’s disability.  Behaviors and specific learning and processing difficulties stemming from a disability are neurological or brain based.

Contrary to what Senator Sessions implied in his speech on the Senate floor, it is absurd to punish a student for a disability he may not have control over. It is unfortunate but punitive and coercive discipline is pervasive in schools today.  Punishment, coercion and a lack of positive behavior supports to prevent inappropriate behaviors produces the opposite affect and fallout in the form of more unwanted behaviors.

The solution to problem behaviors is not to weaken or defund the IDEA but instead to strengthen IDEA and training for educators who may not understand how to shape and teach new behaviors while extinguishing inappropriate behaviors. Senator Sessions thinks the government is already too big and that the IDEA and lack of control by educators is to blame for student behavior.  As US Attorney General Sessions he would be in charge of civil rights – including the civil rights of those with a disability. 
For more information about civil rights concerns See these articles from:  NY Times Article,  CNN Politics,  ABC News,  Equal Justice Society,  Special Needs Digest,  The Atlantic,  ACLU: Jeff Sessions the Facts,  Forbes,  
Autistic Self-Advocacy Network (ASAN),  

Please feel free to leave a comment

Other links of Interest:

10 Supreme Court Cases You Need to Know - Mass Advocates for Children

Since this was posted several weeks ago, the Sessions speech has been removed (like many government documents after the election) from the US Government website. Records of speeches and other government business can be found through the Congressional Record. For your convenience, we have copied the speech (link above in PDF) and HERE in a Word Document.

Another valuable tool to help you evaluate FAKE news sites HERE

Jeff Sessions, gave a speech on the Senate floor in 2000, very critical about the IDEA and even intimating at one point school shootings were a result of allowing disabled students in schools.The speech is and continues to be of concern, Sessions could present a threat to students with disabilities. Since we published this article, his speech has been removed from the website. Sessions has not clarified his views so we can only assume they have not changed. Here are excepts from the speech.

If this information is valuable to you, please like up on FACEBOOK, Tweet this on Twitter and send us a comment.

Prior Written Notice (PWN)

Prior Written Notice is a tool that can be used by parents - a highly effective tool. Take this form (with the requirements for a PWN) to the IEP meeting. Using the form can defuse some of the "ruffled feathers". After all it's not the parents asking for qualification, it's the law. When schools vascilate, ask them to either accept, reject and for dates when services, evaluations etc. will begin or in some cases end.

Download the form

Prior Written Notice – 20 U.S.C. § 1415 of the IDEA

Notification requirements (for PWN)

The content of prior written notice required by subsection (b)(3) shall include:

  • A description of the action proposed or refused by the agency (School District);
  • An explanation of why the agency proposes or refuses to take the action
  • A description of each evaluation procedure, assessment, record, or report the agency used as a basis for the proposed or refused action;
  • A statement (at the time of the PWN) that the parents of a child with a disability have protection under the procedural safeguards of this subchapter
  • If this notice is not an initial referral for evaluation, the means (how) a copy of a description of theprocedural safeguards can be obtained;
  • The sources for parents to contact to obtain assistance in understanding the provisions of this subchapter;
  • A description of (each of) other options considered by the IEP Team and
  • The reason why those (considered) options were rejected; and
  • A description of the factors that are relevant to the agency's proposal or refusal.

ADA Resources

ADA & Disability History

ADA Timeline

Learn more about the history of the Americans with Disabilities Act (ADA) through this historical timeline from the ADA National Network. 

ADA Highlights - George H.W. Bush Presidential Library Museum

This website highlights the ADA, its history, and provides an ADA Lesson Plan, quotes from President Bush about the ADA, and other historical resources.

ADA Exhibit - Presidential Timeline

This virtual exhibit features the ADA as a key piece of legislation signed during President Bush's administration and highlights other related events and issues.

EveryBody: An Artifact History of Disability in America

This virtual exhibit from the National Museum of American History explores the history of disability through the material record of the people who lived it from stereotypes to laws, technology and issues in everyday home life for people with disabilities — How the story unfolds depends on how you, the visitor, shuffle it. Featuring images documenting more than 50-years worth of objects and stories collected by the Smithsonian, the exhibit is the museum’s first to be presented exclusively online which they plan to build upon with additions and frequent updates as well as a vibrant social media presence.

Equality of Opportunity: The Making of the Americans with Disabilities Act - National Council on Disability

Future historians will come to view the Americans with Disabilities Act (ADA) of 1990 as one of the most formative pieces of American social policy legislation in the 20th century. This publication from the National Council on Disability (NCD) reminds us of our past and urges us to press on with renewed and united sense of purpose to deliver on the ADA's legacy, hope, and promise.

General ADA Resources

ADA Service Dog

Revised (2010) regulations for service dogs. Also "Dogs with Jobs" an overview of different kinds of working dogs.

ADA Questions and Answers (Q&A) Booklet

This collaborative publication by the ADA National Network provides answers to common questions on the ADA for employment, state and local government, public accommodations and also offers a quick contact reference for federal agencies and other organizations that provide information about the ADA and informal guidance in understanding and complying with the ADA.

Frequently Asked Questions about the ADA

Find answers to common questions on the ADA and related disability topics — search by keyword, audience and topics. This is a collaborative initiative of the ADA National Network. 

ADA Title II & III Regulations Fact Sheet Series (English) (Español)

The U.S. Department of Justice revised the ADA Title II and Title III regulations. These regulations amend the DOJ Title II requirements for State and Local Governments and Title III requirements for Places of Public Accommodation. Many of the regulations took effect March 15, 2011 with some requirements going into effect March 15, 2012. The ADA National Network developed these Fact Sheets to give guidance on specific changes and an overview of revised regulations by topic.

ADA Anniversary Tool Kit

A tool kit of informative materials on the Americans with Disabilities Act (ADA) for use throughout the year in your celebration of the ADA Anniversary - July 26. This is a collaborative initiative of the ADA National Network hosted by the Southeast ADA Center.

ADA Publications and Fact Sheets from the ADA National Network

Informational materials about the ADA and related disability topics; some materials are also available in Spanish. This is a collaborative initiative of the ADA National Network. 

ADA Web Search Portal

This portal provides a focused search of important websites that contain information about the Americans with Disabilities Act (ADA) and connects individuals with high quality information about the ADA and to assist individuals in answering ADA questions. This is a collaborative initiative of the ADA National Network. 

ADA Quiz Book, 4th Edition

A comprehensive ADA training tool for individual study or group trainings. The 105 pages and 45 activities include quizzes, puzzles and case studies, expanded to reflect recent changes in the ADA. Order and pay online from Meeting the Challenge.

ADA Systematic Review

Research on the ADA includes many different research questions and methods, covers numerous topic areas, and impacts diverse groups of people. Because of this broad range of research, policy makers and researchers are often unsure about the true impact of the ADA. To address this uncertainty, the University of Illinois at Chicago is conducting a three-stage review of the ADA in collaboration with the ADA National Network - National ADA Knowledge Translation Center Project. The first stage of the project is a Scoping Review Summary and a Technical Report of the Scoping Review which involves gathering scientific research and search terms on the ADA.

Ten Things You Need to Know about the ADA

The July 2015 issue of the quarterly newsletter, Disability Connection, from summarizes ten need-to-knows about the ADA.

Technology Access Resources

Accessible Tech - For Accessible Technology In The Workplace

A web portal designed to build a partnership between the disability and business communities to promote full and unrestricted participation in society for persons with disabilities through awareness of technology that is accessible to all. This initiative of the ADA National Network is hosted by the Pacific ADA Center with support from the Great Lakes ADA Center and Mid-Atlantic ADA Center.

Disability Law & Policy Resources

ADA Case Law Database

A comprehensive database tool that tracks major decisions and summarizes the key issues pertaining to significant rulings under the Employment (Title I), Local and State Government (Title II) and Places of Public Accommodations (Title III) provisions of the Americans with Disabilities Act (ADA) searchable by disability type, discrimination issue, jurisdiction and remedy. This collaborative initiative of the ADA National Network hosted by the Great Lakes ADA Center.

ADA Disability Law Handbook

A broad overview of the rights and obligations under federal disability laws available online in web or PDF format. This is a collaborative publication by the Southwest ADA Center and ADA National Network.

Report on the Impact of the ADA Amendments Act (ADAAA) Released by National Council on Disability

The National Council on Disability (NCD), an independent federal agency, released a report in July 2013 titled “A Promising Start: Preliminary Analysis of Court Decisions Under the ADA Amendments Act,” which reviews the court decisions that have been rendered to date applying the Americans with Disabilities Act Amendments Act of 2008 (ADAAA) and reveals significant improvements in how courts are interpreting protections intended for coverage under the ADA.

Business & ADA Resources

Accessible Meetings, Events, and Conferences Guide

This guide will help you navigate, plan, and create successful, inclusive meetings, events and conferences. Features include: plan a meeting, attend a meeting, speakers/presenters tips, training materials, employers guide, operations, publications, and resources. This guide from the Hospitality and Disability initiative of the ADA National Network is hosted by the Mid-Atlantic ADA Center, in collaboration with TransCen, Inc.- Career and Workforce Development.

Hospitality and Disability Initiative

A web portal designed to promote accessibility and opportunity for people with disabilities in the hospitality industry. Materials, resources, and training aim to help hospitality businesses expand their market share by effectively reaching and serving customers with disabilities, and are also designed to assist lodging and food service employers recruit, hire, and retain qualified workers with disabilities. This initiative of the ADA National Network is hosted by the Mid-Atlantic ADA Center, in collaboration with TransCen, Inc.- Career and Workforce Development.

Employment & ADA Resources

Just-in-Time Toolkit for Managers: Building a Disability-Inclusive Workforce

This toolkit is divided into ten topics based on a disability issue that managers typically encounter in the workplace. Each topic has been designed to be used in about five minutes. If you choose, each topic also contains links to test your knowledge, print a one-page checklist, and pursue further resources. This is a collaborative initiative of the Northeast ADA Center, a member of the ADA National Network and a program of the K. Lisa Yang and Hock E. Tan Institute on Employment and Disability at Cornell University.

Government & ADA Resources

My Heroes Have Always Been Cowboys: Special Education Parent Advocacy

Cowboy Heros

Cowboy Heros [Webinar based on this article is scheduled for October 22 at 7:30 PM ET Register Here To get notification of future articles & webinars - sign up here] My heroes have always been cowboys

And they still are it seems

Sadly in search of and one step in back of

Themselves and their slow moving dreams.[1]

That is a passage from my friend Sonja Kerr’s favorite song. As it turns out it is one of my favorites as well.

Several years ago Sonja and I were thinking of writing an advocacy book together. We were going to open the book with that passage.

The book didn’t happen.  So after all these years I’m pulling it out again for this article, which continues our conversations about how to read a case; hearings; getting ready for hearings; and other topic suggestions we received from  some of our Inside INCIID webinar participants.

This summer drove home the “slow moving dreams” part of the lyric. Time was when not much happened during the summer for parents and special education. It might be just my little operation, but this summer has been anything other than slow moving. Team meetings, correspondence with schools, complaints, and other sticky special education problems went on during this summer just as if school was still in session.

So for me, parents of children in special education are truly heroes just as in the lyric, are “Sadly in search of and one step in back of Themselves and their slow moving dreams.”

The whole point of this series of INCIID articles is to show and teach how any parent can become a more effective advocate for their own child. INCIID wants to show how advocacy is more than being special education rules and procedures expert.

Parents are the watch guards stationed along the front lines of enforcement of the civil rights protections that created the foundation upon which Congress constructed the federal law we now know as the I.D.E.A. The I.D.E.A. is an enforcement statute that was enacted to ensure that public schools provide a free appropriate public education to each eligible disabled school age child in America.

Without effective direct parental advocacy a student's education can get lost in the "pieces" and jargon that fill the bureau drawers in which special education and related services are stored. Special education today is not only a bureaucratic maze in its finest form, it is also a very large industry. Somehow, the language of special education has created a schism between the public interest goals of providing disabled children an appropriate education in the general curriculum and the way it is experienced in the classrooms across the country. Somewhere along the way since Congress enacted the EHA and later the IDEA competing interests began to obscure the civil rights vision underlying the IDEA and Section 504 that each human being is worthy of being treated with dignity and respect.

So yes, parents are heroes. And yes, just as this past summer demonstrated to me, parents continue through the summer trying to pry an appropriate IEP or 504 plan from the drawers that seem to be slammed shut.

 A few weeks ago I admitted making a big mistake in the JD v Paulette School District case. Some of you asked what my mistake was. I answered by telling the truth about my mistakes. I also mentioned that I was vocal about the hearing officer’s handling the hearing. What I didn’t include was the passage I wrote into the written closing arguments for the due process hearing. The passage was -

“Will all those who feel powerless to influence events please signify by maintaining their usual silence.” From and Ashleigh Brilliant Post Card.

There are many reasons why that quotation in a formal paper was a mistake. Chief among the reasons is the structure of formal disputes Congress incorporated in the IDEA.

Due process of law

“n. a fundamental principle of fairness in all legal matters, both civil and criminal, especially in the courts. All legal procedures set by statute and court practice, including notice of rights, must be followed for each individual so that no prejudicial or unequal treatment will result. While somewhat indefinite, the term can be gauged by its aim to safeguard both private and public rights against unfairness. The universal guarantee of due process is in the Fifth Amendment to the U.S. Constitution, which provides "No person shall…be deprived of life, liberty, or property, without due process of law," and is applied to all states by the 14th Amendment. From this basic principle flows many legal decisions determining both procedural and substantive rights.”  Law.Com, 

Due Process and Section 1415 of the IDEACourtroom

20 USC Chapter 33, Section 1415 of the IDEA contains every procedural safeguard from how parents receive Prior Written Notices to the procedures for all of the available dispute resolutions.

Due process and the impartial hearing officer

First, we must understand that the hearing officer is the cornerstone of a “legal” hearing. Why? Because the fundamental goal of an impartial due process hearing is to find out what happened and decide what to do about it.

The primary constitutional requirement in the IDEA that relates directly to hearing officers is that they be impartial.

The definition of impartiality that has been developed over the years for hearing officers is not nearly as rigid and demanding as that applied to judges. Factors do exist which require hearing officers to disqualify themselves for a lack of impartiality.

Consider: A former school administrator left teaching and later attended law school and was admitted to practice law in the state. The former teacher then became a hearing officer under the rules for hearing officers in the state school code. Over the span of his teaching career, the hearing officer developed a skeptical attitude toward parents and their willingness to tell the truth. The hearing officer carried his skeptical attitude into the hearings assigned to him. The Second Circuit said, "Our conception of an impartial decision maker is one who, among other things, does not prejudice the evidence and who cannot say, with the utter certainty advanced by these defendants, how would assess evidence he has not yet seen." Benjamin v. Coughlin, 905 F.2d 564 (2nd Cir. 1990).

The hearing officer plays a critical role in controlling the hearing process by applying the rules, conducting the hearing in a fair manner, and that the hearing meets the goal of evaluating the accuracy of the petitioner’s claims and the relevance of the evidence the parents and the school district presents.

In other words, the hearing officer is the fail-safe for protecting the student from a denial of a free appropriate public education.

The Hearing Officer Must Take An Active Role in the Hearing

Special Education Due Process Hearings resemble court trials, but they are not trials. Instead, a due process hearing is a unique form of administrative proceeding designed particularly to meet the needs of the state department of education as it enforces the I.D.E.A.

One way in which special education hearings differ from a trial is the role played by  the hearing officer. In the American legal system, the trial judge plays a relatively passive role. The lawyers representing the two sides take the lead in introducing evidence. Although a judge may question a witness in a trial, judicial questioning is the exception not the rule. 

The ultimate goal is not to find in favor of the school district or the parent. The goal is to determine the truth of the claims brought by the petitioner and render a decision accordingly.

The hearing officer is continually called on to make judgment calls. For example,  which of two conflicting witnesses to believed; what was "reasonable" under the circumstances of a particular case; what is appropriate; should a particular document be allowed as evidence; etc.

Each party should be given a reasonable opportunity to present their case. This does not mean allowing a party to talk or argue as long as they want.

Giving reasons for rulings both on the merits of the case and on other discretionary decisions the hearing officer may make during a hearing

Did it feel good to write that quotation into the written closing arguments in the JD v Paulette School District case? You bet it did. And that was my mistake. I could have filed a grievance against the presiding hearing offices with the Vermont Department of Education instead of dragging up the Ashley Brilliant quotation to do the dirty work. I will never know how much damage, if any, putting that quotation in the closing arguments. To this very day I regret having done it


[1]             From Willy Nelson's version of the song, My Heroes Have Always Been Cowboys. 


Case Analysis: You don't have to be a lawyer to learn to think like one!

Thinking like a lawyer

Thinking like a lawyerA Conversation with Brice Palmer

[Note: Watch the Webinar CASE Analysis., with Speaker Brice Palmer about thinking like a lawyer and getting the appropriate services. Download the Webinar Handout 
In our first INCIID article we said you don’t have to be a lawyer to be a good parent advocate; “You just need to know how to think like one.”

Well – surprise, surprise. If you Google the term “think like a lawyer” you will find lawyers do not have a universal definition of what thinking like a lawyer means. There are thousands of articles, blog articles, academic papers, and web sites that talk about what it means to think like a lawyer.

Experience taught me that parents are far more aware of what their child’s special education problem is than others realize. The rub comes when parents do not know how to explain the problems in a way the procedural system deals with resolving problems.

The one word that appears in all the articles I read about thinking like a lawyer is the word analysis.

Analysis goes like this –

  • What’s the big deal here?
  • Are there any rules that tell us how to deal with the big deal?
  •  Is there any credible proof (facts) that the big deal really is a big deal?
  • What rules tell us how to formally complain about the big deal, and 
  • Where can we find insights into how the big deal deciders have decided big deals?

This article is intended to introduce you to the first basic concepts about how to read a case. There is a hypothetical practice exercise on the last page 5 of this article. You will find this is a completely different way to look at cases and what they mean. It takes time and practice. Isn’t easy – and you can do it.

Raise your hand and say I can do it.

The one word that appears in all the articles I read about thinking like a lawyer is the word analysis.


1. Do not read the opinion word for word. Look for the structure. Once you fully understand the structure you can then learn how to read an opinion or decision. Once you master the structure your life will change when it comes to planning for a Team meeting or writing a state administrative complaint or a request for a due process hearing.

2. Print the decision. A printed page is much easier to read than reading text on a screen.

The structure

1. The Caption

At the top of the first page of any legal opinion is the caption. The caption is comparable to a title. It tells us who is who is complaining against whom (the parties to the dispute) which court or hearing authority issued the decision, and the dates.


J.D. EX REL. J.D. v. PAWLET SCHOOL DIST., 224 F.3d 60 (2nd Cir. 2000)

J.D., by his parent, J.D., Plaintiff — Appellant, v. Pawlet School District,

Bennington-Rutland Supervisory Union, Vermont Department of Education, and

Mark Hull, in his official and individual capacity, Defendants — Appellees.

No. 99-9263.


United States Court of Appeals, Second Circuit.
Argued June 30, 2000.
Decided August 15, 2000.

You can read J.D. v Pawlet online and download a pdf copy here:

Full disgraceful disclosure: I was the advocate who conducted the due process hearing, found a lawyer for the review by the US District Court and the appeal to the Second Circuit. I cannot adequately describe all of the mistakes I made in that case. Feel free to ask.

Though the style might change slightly from jurisdiction to jurisdiction, the information in the caption remains the same.

Next, the decision contains a short history about how the case came to the court or administrative hearing officer or judge. The short history or background information may include the procedural history of the dispute. It might also include some factual information. You can recognize this section by its position just below or near the caption.

This is the short history from JD v Pawlet School District:

 “J.D., by his parent J.D., appeals from a final judgment of the United States District Court for the District of Vermont (Jerome J. Niedermeier, Magistrate Judge), granting the defendants-appellees' motion for summary judgment dismissing the complaint in its entirety. The district court held that: (1) J.D. failed to meet the "adverse effect" eligibility criterion of the Vermont Department of Education Special Education Regulations ("VSER"), which implement the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. § 1400 et seq.;[fn1] (2) the defendants-appellees did not discriminate against J.D. in violation of § 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794; and (3) J.D. was not entitled to relief based on alleged violations of certain procedural safeguards in the IDEA. We affirm.”

Following the procedural history you will find a discussion of the facts. The facts are only the facts the court found as relevant to JD’s claims. All special education cases under the IDEA that wind up in a court are decided without a jury. That means the judge (and for that matter a hearing officer or law judge) determines which facts presented by both sides are facts that are relevant to the issue complained about by the parent or the school district (if the district files the request for a hearing). It also means the judge or hearing officer is the sole determiner of the applicable law for the case.

This section of the decision is generally labeled Facts or something like that. In JD v Pawlet School District the sub-title of the fact section is


A. Factual Background

(JD v Pawlet pdf version, Pages 2-4)  

Some decisions describe the facts of the case in numbered paragraphs. Others write the facts in paragraphs without numbers.

Following the facts as determined by the judge or administrative hearing authority, the author of the decision describes the laws that apply to the case in great detail. In JD v Pawlet School District, the court sub-titled this section


A. Standard of Review

(JD v Pawlet pdf version, Pages 4-12)  

In this section the court meticulously described the claims JD made in his complaint and applied the law to each of those claims. At the end of each of the claims discussion the court published its ruling for that particular claim.

III, Conclusion

(JD v Pawlet pdf version, Page 13)  

“For the reasons explained above, the judgment of the district court is affirmed.”


Once you know how these things are written the light will come on. You will know how to make more persuasive presentations to the Team, write more effective letters to the school, and decide whether you have enough information to think about exercising your administrative complaint or hearing rights under the procedural safeguards.  You will also be able to decide whether you have enough factual information to file an OCR complaint letter. The upshot is that you can make reasoned decisions instead of going on a gut feeling.

Hypothetical exercise.

Background and facts:

The Old Overshoe School District superintendent notified all parents with children in grades 1 – 12 in the District that students at Old Overshoe are required to bring an electronic tablet or pad to school beginning on the first day of school for the 2015-2016 school year.


The students will use the tablet or pad throughout the school year for taking classroom notes, doing their homework, and taking tests and examinations. The parents are required to purchase the tablet.

There is no exception to this rule. The notice from the superintendent went to parents to their last known email address and by US Mail to the parent’s home address of record.

Question: Under what set of facts and the IDEA or Section 504 might the Old Overshoe School District’s requirement (a) be found to be a denial of FAPE and/or (b) discrimination on the basis of handicap or disability?

Helpful tools:

The Law Dictionary

Legal citation

Have fun.


You are invited to post a question for Brice about this article or any other special education question on the INCIID Ask The Advocate Forum by going to

Download the Article in PDF

What Does "Appropriate" Really Mean?

What exactly does appropriate mean as far as IDEA goes?

by Brice Palmer

What exactly does appropriate mean? [NOTE: Register for the Webinar on Thursday July 16, 2005 7:30 PM] The question about what the word appropriate means in the IDEA is one of the most important questions you can ask.
The fundamental concept of the word appropriate is- compared to what? 
How do we know how to compare (in the IDEA) what is appropriate and what is not appropriate (inappropriate)?
Let me disclose again that I am not an attorney and I am not a legal scholar by any stretch of the imagination. 

Statutory interpretation
Answering our question about what does the word appropriate mean in the IDEA must begin with something called statutory interpretation. Don't panic. It isn't as scary as it sounds. 
Statutory interpretation is the process courts use interpret and apply legislation. Interpretation is sometimes necessary when a case involves a statute. Sometimes the words of a statute have a plain and straightforward meaning. 

There are instances, though, that some ambiguity or vagueness in the words of the statute require a hearing officer or judge to resolve the ambiguity.
Hearing officers and judges use various tools and methods to interpret language in a statute. Some of those tools are long standing principles and rules of statutory interpretation, legislative history, and purpose. In the courts in the U.S., judges may apply rules of statutory interpretation to legislation passed by the legislature or is delegated legislation. Delegated legislation can be in the form of administrative agency regulations.   

We touched on this subject earlier in this series of INCIID articles.
Assume, for example, that a statute requires that cell phone use while driving a motor vehicle is a violation of the state motor vehicle code.  If the statute (code) does not define the term "motor vehicles", then that term will have to be interpreted if questions arise in a court of law. 
In an earlier INCIID article we did this exercise when the question was whether a snowmobile is (in the state in question) defined as a motor vehicle. In that hypothetical Bubba was driving his snowmobile on a city street, was pulled over and given a ticket for talking on his cell phone while driving a motor vehicle. In our hypothetical the state motor vehicle code did not include snowmobiles in the definition of a motor vehicle.

The question for us is "what does the word appropriate" mean in the IDEA? 
The IDEA itself tells us what appropriate means. If we can prove the IDEA defines the word appropriate we can take comfort in a few US Supreme Court decisions that tell us we are on the right track.
"We begin with the familiar canon of statutory construction that the starting point for interpreting a statute is the language of the statute itself. Absent a clearly expressed legislative intention to the contrary, that language must ordinarily be regarded as conclusive.:" Consumer Product Safety Commission et al. v. GTE Sylvania, Inc. et al.,447 U.S. 102 (1980). 
"[I]n interpreting a statute a court should always turn to one cardinal canon before all others. . . .[C]ourts must presume that a legislature says in a statute what it means and means in a statute what it says there." Connecticut Nat'l Bank v. Germain, 503 U.S. 249 (112 S.Ct. 1146, 117 L.Ed.2d 391). And, "[w]hen the words of a statute are unambiguous, then, this first canon is also the last: 'judicial inquiry is complete.' Connecticut National Bank v. Germain, (1992)" 503 U.S. 249, 254.

The US Supreme Court recently decided two cases in which statutory interpretation and constitutional (language) interpretation was a big deal. I mention these two decisions because lawyers and scholars will study, write, and debate these two decisions for decades. Although the subject of each of the cases are different, the cleft between the majority opinions and the dissenting opinions are wide and woolly. 
King v Burwell,  576 U.S. ___ (2015) 

Question presented (to the Court): 
Section 36B of the Internal Revenue Code, which was enacted as part of the Patient Protection and Affordable Care Act, authorizes federal tax-credit subsidies for health insurance coverage that is purchased through an "Exchange established by the State" 
The question presented was whether the Internal Revenue Service may publish regulations to also extend the tax-credit subsidies to insurance coverage bought through Exchanges established by the federal government. In this case, even the meaning of a capital S or a lower-case s received a great deal of attention. 
Obergefell v.Hodges, 576 U. S. ____ (2015) 

Two questions presented:
1. Whether the Fourteenth Amendment requires a State to license a marriage between two people of the same sex. 
2.  Whether the Fourteenth Amendment requires a State to recognize a same-sex marriage licensed and performed in a State which does grant that right.
You can read both of these decisions at and
The legal literature and case decisions on statutory interpretation is enormous and goes back several centuries - way before there was a United States. 
Still, we meeting navigators must have a way to come to a reasoned decision about what is and what is not appropriate in an IEP. 
The unfortunate problem is that we assume we know what is or is not appropriate. It also seems many school district people also assume they know what appropriate means. 
It is also true that (in my experience) parents often have a keen instinct about what is and what is not appropriate in their child's IEP. The problem, though, is many of them do not know how to prove their intuitive conclusion. And without being able to prove it, they lose.
This magic formula will help you know when someone pulls the old switcheroo about what is or is not appropriate for your student.
What does the IDEA statute say? Remember from the discussion earlier that we should not read a section of a statute isolated from the context of the whole act? And that when a court interprets legislation it must not be guided by a single sentence or part of a sentence? And the court (and us) should look to what the whole law provides as well as the legislation's object and policy? (Paraphrased from Richards v. United States, 369 U.S. 1, 11 (1962).

Begin at the beginning.
The IDEA begins with the Act, which Congress wrote and passed. The Act is the Individuals with Disabilities Education Improvement Act of 2004.  You will find the congressional purpose of the law and other important information about what Congress (the legislature) intend the IDEA to be and do in the Act. 
The Act is then put into statutory law, which is located at 20 U.S.C. 1400. You can find it here:
The US Department of Education then writes regulations that implement the statutes. The regulations are located in the Code of Federal Regulations (CFR) Chapter III. You can find it here:

Do you need all of that information for your day-to-day dealings with the school district? 
No, but knowing where you can find it is important when you need it.

For analyzing FAPE, we begin with the definitions at 20 USC 33 §1401. 
20 USC 33 33 §1401 (9) Free appropriate public education

The term "free appropriate public education" means special education and related services that-
(A) have been provided at public expense, under public supervision and direction, and without charge;
(B) meet the standards of the State educational agency;
(C) include an appropriate preschool, elementary school, or secondary school education in the State involved; and
(D) are provided in conformity with the individualized education program required under section 1414 (d) of this title.

Read this carefully. Do not look at it and say sure, I've seen that before. 
Read each line. If any sub part (A through D) is not met you may be looking squarely in the eye of a denial of FAPE. For example, we all know the F in FAPE means free. But read (A) again - Free is just one of three separate parts of (A). 
Read (B). Have you looked at your State's learning standards? So far I have not found one State's learning standards that exempt students who have an IEP or FAPE under a 504 plan.
To me, appropriate for a specific student means each element of the definition of FAPE at 20 USC 33 33 §1401 (9) must be met. 
When we are deciding whether an IEP is appropriate we can use the same method hearing officers and courts use to analyze a legal question (issue). An issue is usually stated something like this: 

Whether the Old Overshoes School District denied the student a free appropriate public education by telling the parent ESY is available only during the three weeks during the summer beginning two weeks after the end of the school year.

Where would that issue appear in 20 USC 33 33 §1401 (9) Free appropriate public education? You are on good ground if you chose (D) are provided in conformity with the individualized education program required under section 1414 (d) of this title. 

You can read Section 1414 (d) at NOTE: Scroll down the page or term search (d) Individualized education programs.
Continue reading through to (e) (Educational placements
The Federal Regulation:
34 CFR §300.17. You can read it at
34 CFR § 300.320
Definition of individualized education program. You can read it here:

If you find using the references cumbersome I recommend getting a copy of Wrightslaw, Special Education Law, 2nd Edition. This is the most authoritative and easy to use book about the IDEA statutes, regulations and more. And no, I am not affiliated in any way with 

So in plain language, what does appropriate mean in the IDEA? I hope this article will help you define it when you suspect you see it.

Synonyms for appropriate used as an adjective:
Applicable, apt, correct, fitting, good, opportune, pertinent, proper, allowable, acceptable, applicable, fair, just, justifiable, lawful, legal, and legitimate.    
In passing: Consider putting together a local parent study group to nail these analysis concepts down.

Have fun.
Best regards.

You are invited to post a question for Brice about this article or any other special education question on the INCIID Ask The Advocate Forum by going to


Words have Meaning: Respectful Adoption & Person First Language


adoptionWords Have Meaning

I first learned about the use of Respectful Adoption Language (RAL) from Patricia Irwin Johnston more than twenty years ago. RAL refers to attribution of “maximum respect, dignity responsibility and objectivity when working and communicating about adoption. The term was introduced originally by a social worker named Marietta Spencer.

          Some may think this is about political correctness. It is not. Some words in different settings and scenarios have the ability to be emotionally charged and not in a good way. For example asking a mom if the child in tow is their “natural child” as opposed to what – an unnatural child? Or asking, “Is that your real mother?”  Really, use of RAL can diffuse the emotional overcharging that comes with adoption.  Use of RAL validates that those carefully planning an adoption placement are thoughtful and practical people trying to made the best child-centered plan for the baby in question. After all, the adoption triad while a happy event for the intended parents may be devastating for the mother who places her child with an adoptive family. There is always loss within the adoption triad (even if it is not evident). It is common for many individuals to throw language and adoption terms around without thinking or necessarily having the “real” and complex family experience of adopting a child.

The application of respectful use of language is really common sense (which appears to be often in short supply).

What Constitutes a Family?

Historically people are considered members of a family when there is a “blood” relationship or strong social link to the other family members. (i.e. marriage between men and women, father and mother to children, siblings and their offspring) but an adoption links parents to their child by love and the law. Have you ever heard anyone a relative by saying, “this is John’s adopted son Harry”? Or worse having a parent introduce their child by saying, “This is our adopted daughter, Karen.” Would anyone introduce their child by qualifying their introduction with, “Hello, this is my vaginal birthed child, Jeff.” or “This is my vasectomy failure daughter Jesse.”?  I think not. These are introductions suggestive of relationships are abnormal or not as genuine as “blood relationships”. Asking anyone if someone who raised them is their “real mother” is disrespectful and filled with negativity. Because my younger child is not white (like her sibling and parents) and has a disability, we are often asked, of we knew she had disabilities before we adopted her. As if to suggest maybe we could return her and get a refund!

Family definitions change as people become more enlightened. Any two people that make a commitment and chose a life together are a family. It matters not whether they decide to live childfree, give birth to half a dozen children or adopt a child. Making the decision to parent is based on intent.

Person First Language Parallels Respectful Adoption Language

A relationship exists with person first language and respectful adoption language. Those who have a disability are often referred by their disability label (autistic, wheelchair bound, disabled). This type of language can attach a disability to the person and ignore the individual personalities and characteristics that make that person who they are. Instead of incorporating their disability into their description, (Autistic) putting the person first (young man with a diagnosis of autism) emphasizes the person and not the disability. Person first language was adopted by psychological community to try to de-stigmatize persons with disabilities. There is a parallel with person first language and RAL.  Paying attention to person first and respectful adoption languages makes us think about our words and reflect on them. Words have meaning and should carefully select words to convey meaning.

Labels can degrade and objectify people. They can dehumanize and humiliate too. People should not be labeled. When meeting a person the only expectation should be who that person is as an individual.  Family-building through the act of adoption (and those with disabilities) all want the same thing as the rest of the population. We all want to be treated with respect and dignity. If we label people as “adopted from (you fill in the blank) or wheelchair bound or intellectually challenged, we handicap their prospects by having already defining them with some type of negative language. Keep expectations high, select words carefully and enjoy everyone as a unique individual by using respectful adoption and person first language. 

Advocacy: Parental Participation

Advocacy special education - Asian girl walking to schoolParental participation.

By Brice Palmer

Is it a right?

[NOTE: Come to the Webinar with Brice Palmer speaker and bring your questions about parental rights and participation. REGISTER HERE. ] 

Parental participation has trickled up to near the top of the list of what irritates many parents.  I don’t know how widespread that irritation is. What I can say is many parents who get in touch with me are furious about getting shut out of being able to take a worthwhile role during IEP meetings.  Specifically, parents tell me that they resent facilitators or compliance officers who dominate the IEP meeting conversation.

That word “meaningful” is what school districts seem to quibble over.

We say the IDEA gives parents a right to take part in IEP meetings and develop the IEP.

What is a right?

And what gives parents the right to participate in a meaningfully way?

According to W.W. Buckland, the word right is “one of the most ambiguous words in the English language”.[1] When we use the word right in special education we mean that we have an interest or expectation guaranteed by law.[2]

The IDEA guarantees a parent’s right to participate, right. Oh yeah, you say? And you know Mr. Garner’s description of a right isn’t the way it works in your school district, right? You have the law on your side, right?

Mark your calendar for August 24, 2015. That day is the 1,605th anniversary of the first sacking of Rome by the Visigoths. As the story goes, the barbaric Visigoths led by Alaric banged on the gate of Rome demanding entry to the city. The Romans replied saying, you cannot come into Rome – we have laws.

To which the Visigoths replied – we have weapons and a nasty temperament.

Rome fell.

It was the nature of the Visigoths to break things. Rome relied on its laws thinking the Visigoths would appreciate that a law is a law.

Warning: I am neither an attorney nor a legal scholar. What follows is the result of a little poking around to see what some heavyweight decision makers have said about a parent’s right to “meaningfully” participate. 

The trail begins in 1988[3] when the US Supreme Court said Congress provided the team that develops the IEP must include the parents, 20 U.S.C. § 1414(d)(1)(B)(i), and must consider “the concerns of the parents for enhancing the education of their child,” citing 20 USC § 1414(d)(3)(A)(ii). In addition, the Court said, ([t]he IEP team must “revise the IEP as appropriate” to address information about the child provided by the parents. Honig v. Doe, 484 U.S. 305, 311 (1988).

These principles are also a part of the US Supreme Court’s opinion in a case called Board of Education. v. Rowley, 458 U.S. 176, 179 (1982)

The IDEA preserves those principles by “ensur[ing] that all children with disabilities have available to them a free appropriate public education” and by “ensure[ng] that the rights of children with disabilities and parents of such children are protected.” 20 U.S.C. § 1400(d)(1)(A) & (B). You can read the rule at

In 2005 the US Supreme Court issued its opinion in Schaffer ex rel. Schaffer v. Weast, 546 U.S. 49, 53 (2005) (“Parents and guardians play a significant role in the IEP process.”).

The school district must provide a free (and) appropriate public education “in conformity with” the child’s IEP. 20 U.S.C. § 1401(9). In particular, the child’s educational placement must be “based on the child’s IEP.” 34 C.F.R. § 300.116(b)(2) (formerly § 300.552(b)(2)). Finally, parents must be members of “any group that makes decisions on the educational placement of their child.” 20 U.S.C. § 1414(e).

The US Supreme Court has not swayed from those principles.  In 2007, the US Supreme Court wrote in a case called Winkelman ex rel. Winkelman v. Parma City Sch. Dist., 127 S. Ct. 1994, 2000 (2007):

“This Court consistently has recognized the critical importance of the IDEA’s procedural protections. Rowley, 458 U.S. at 205 (“the importance Congress attached to these procedural safeguards cannot be gainsaid”).

And, the Court said,

“(parents enjoy “enforceable rights” at the administrative stage and in federal court). The Court concluded that “[t]he IEP proceedings entitle parents to participate not only in the implementation of IDEA’s procedures but also in the substantive formulation of their child’s educational program.”

“It seems to us no exaggeration to say that Congress placed every bit as much emphasis upon compliance with procedures giving parents and guardians a large measure of participation at every stage of the administrative process, see, e.g., §§ 1415(a)-(d), as it did upon the measurement of the resulting IEP against a substantive standard.”

Active participation on the part of parents is an important principle in the procedural safeguards the Court was talking about. An important part of the mandatory procedural safeguards is to secure the rights of parents to have an active role in educational decisions concerning their disabled child. That is set into the law at 20 U.S.C. § 1415(b)(1) (parents must be given the opportunity to examine all records relating to their child and “to participate in meetings with respect to the identification, evaluation, and educational placement of the child, and the provision of a free appropriate public education to such child”. You can read it here

Yet, it seems many parents are marginalized by the school district during meetings and follow-up correspondence. And, we often argue that there are laws that give us the right to actively and substantially participate (meaningfully).

Aren’t we a little like the Romans when we say to the school, you can’t cut us out of the decision loop because there are laws that give us the right to participate? And doesn’t the school reply with something similar to what the Visigoths said – we have weapons and a nasty temperament?

What is more important; that we understand the nature of the laws or to understand the nature of people?

What good is a right if we aren’t able to enforce that right?

The history of parental participation goes back a long time – and – that history is an eye opener.

Letter to Gramm, Office of Special Education and Rehabilitative Services

June 12, 1990. 17 IDELR 216, 17 LRP 1294

‘Under EHA-B, the special education and related services required by a child with handicaps must be contained in the child's individualized education program (IEP). 34 CFR Part 300. Placement decisions must be based on the child's IEP. School districts must afford the parent every opportunity of participating in the IEP meeting. [EHA-B, requires that each child's IEP be developed, reviewed, or revised at a meeting between parents and school officials, which must occur at least annually. 34 CFR §§ 300.343-300.344.] Under EHA-B, parents "are expected to be equal participants along with school personnel" at all IEP meetings. Appendix C to 34 CFR Part 300 (Ques. 26). The IEP meeting serves as a communication vehicle between parents and school personnel, and enables them, as equal participants, to jointly decide upon the child's needs, the services to be provided, and the anticipated outcomes. If, during the IEP meeting, parents and school staff are unable to reach agreement, the agency should remind the parents that they may seek to resolve their differences through due process procedures. Appendix C to 34 CFR Part 300 (Ques. 33). Every effort should be made to resolve differences between parents and school staff without resort to a due process hearing (i.e., through voluntary mediation or some other informal step). However, mediation or other informal procedures may not be used to deny or delay a parent's right to a due process hearing. Ibid. I am enclosing for Mr. Donaldson's information a copy of questions and answers about IEPs that appear at Appendix C, 34 CFR Part 300 (Ques. 26-35).

Notice that the history of OSEP and the courts discussing parental participation is about the law, but they are also speaking between the lines to human nature. 

Question: As we advocate for a child, is it more important for us to concentrate on the nature of the law or to concentrate on the nature of people?


About the author:

Brice is a special education advocate who works with parents across the country. He has practiced, taught and written about special education advocacy since 1995.  His articles have appeared in The Beacon Journal, published by Harbor House Law Press, Autism Asperger’s Digest, published by Future Horizons, Inc., Family Focus, the quarterly newsletter published by Families for Russian and Ukrainian Adoption (FRUA), and various articles appearing at Some of the Wrightslaw articles are: Do the Documents Speak for Themselves?How to Prepare Your CaseLearning To Negotiate Is Part of the Advocacy Process, and How and Why to Tape Record Meetings.

Brice lives out in the woods near Benson, Vermont.  Your can reach him by phone at (802) 537-3022. 
Brice also answers questions on the  Educational Advocate Forum so all can benefit from the answers. or you can Email him.

[1] W.W. Buckland, Reflections on Jurisprudence 32, 1945,

[2] Garner’s Dictionary of Legal Usage, Bryan A. Garner

[3] Congress passed the Education for All Handicapped Children Act (“EAHCA”) in 1975. In 1990, Congress changed the name of EAHCA to the Individuals with Disabilities Education Act (“IDEA”).

IEP'sWebinar: Are Like a Box of Chocolates - You Never Know What You're Gonna Get

Webinar - IEPs educational jargon

Webinar - IEPs educational jargon

Direct Link to the Recording

[Note: Webinars are recorded using GotomyWebinar by Citrex. For some reason the first 10 minutes of this presentation did not record. However the majority of the presentation is here. If you have questions, please do not hesitate to email INCIID or Brice.]

“My momma always said, life is like a box of chocolates. You never know what you're gonna get.” 
Forrest Gump 

Isn’t the “You never know what you’re gonna get” feeling what you have when you finish the annual review, go through several draft versions, and the district gives you the final IEP—and asks you to approve it? 

When you do get a copy of the final IEP you’re worn down. In one-way or another the whole meeting routine became less about your child and more about personalities and the school district. An onlooker might describe the serial IEP meetings for the annual review as an old fashioned goat roping contest. 
Are the present levels and the annual goals so elastic that explaining them after the fact in ways to explain away how the district implemented them? 
They aren’t, you say? 
But what do you do about it? 

There is a dark side to using educational jargon. Brice Palmer discusses the importance of language, clear  concise writing and getting rid of educational jargon in IEPs.
This webinar was recorded on June 10, 2015.  If you have questions, please post them to Brice here.

This webinar is based on the article: IEPs are like a box of chocolates. You never know what you're gonna get!

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