Facts of the Case
In 1993, an eleven-year-old Mark Hartmann with autism spectrum disorder (ASD) was a first-grade student at Ashburn Elementary School in Loudoun County, Virginia. Mark studied in a regular classroom but received special education services during lessons and in school. Mark had a fulltime aide and was enrolled in speech/language therapy during his time in school. Ashburn Elementary School’s staff were thoroughly trained on autism and ensured that they facilitated communication and inclusion of all students. When in the regular education classroom, Mark engaged in problem behaviors such as hitting and punching, undressing, kicking and biting, and loud screeching. Mark also had limited communication skills and struggled with writing despite using a canon device to assist him.
Mark attended Butterfield Elementary School in Indiana for his preschool. The educational setting was divided into self-contained and regular classrooms. Later, the parents moved to Virginia, where Mark attended Ashburn Elementary School. As the school year ended for his first grade, Mark’s Individualized Education Program (IEP) reported that the child was not making any academic progress. The IEP team proposed that Mark be moved to a segregated district school with an autism classroom. The school suggested that he could go back to his regular classroom with specialized education if he showed the ability to control his behavior. However, Mark’s parents, Roxanna and Joseph Hartmann, refused to sign the IEP ( Hartmann v. Loudoun County Board of Education , 1997). The parents asserted that the county was not complying with the provisions of the Individuals with Disabilities Education Act (IDEA). Following the above scenarios, the district filed a due process hearing for the case.
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Procedural History
Mark’s Individualized Education Program (IEP) decided to place him in Leesburg Elementary School, where he would study in a self-contained setting with five other autistic students. However, Mark’s parents did not approve the IEP team’s decision and complained that it did not meet IDEA’s enforced laws. In December 1994, a local hearing was held, and the officer upheld what Mark’s IEP team had proposed. The local county hearing officer concluded that Mark’s behavior was disruptive. The child did not also receive any educational benefit in the regular education program despite the school county’s efforts. Later in May 1995, a state review officer affirmed the local county officer’s decision ( Hartmann v. Loudoun County Board of Education , 1997). Hence, the initial judgement affirmed Ashburn Elementary School’s decision about Mark’s inability to progress in academics.
Mark’s parents, Roxanna and Joseph Hartmann, challenged the local court’s decision in a federal court. The District Court rejected the administrative findings and reversed the hearing officer’s decision. The federal court stated that an administration should not use disruptive behavior as a determining factor of the appropriate educational setting to place a disabled child. The District Court also concluded that Mark did not receive a significant educational benefit because the school did not take appropriate measures to assist him in a general education classroom ( Hartmann v. Loudoun County Board of Education , 1997). Later, Loudon County appealed, and the Appellate Court ruled the Supreme Court stated that the IDEA does not provide the federal courts did not qualify to rule the case. The District Court did not have a license to substitute its views of sound educational policy with those of the school’s authority. The Appellate Court found out that the administrative findings were accurate and that Mark did not make any academic progress despite the school’s efforts. Hence, Mark needed to be placed in a self-contained classroom that offered education to those with disabilities.
Issue
Various issues were present in Hartmann v. Loudoun County Board of Education . The first one was regarding Mark’s placement, where he should be educated; in a general or special education classroom. The second issue was the extent to which Mark’s behavior problems became a “disruptive force.”. The final issue was about qualifications; whether teachers and professionals working with Mark were adequately qualified.
Holding
The final ruling was that of the Appellate Court that denied the request that Mark’s parents made. The court ruled that Mark would not remain in the general classroom but should be placed in a school with autism classes. Despite receiving specialized education in a regular classroom, Mark did not make any academic progress. Loudon Country supported what Mark’s Individualized Education Program (IEP) team had proposed at the end of his first-grade year. Thus, Mark was to be placed in a self-contained classroom so that he could receive a beneficial education.
Judgement
The Appellate Court’s decision reversed and remanded the District Court’s ruling. The Appellate Court found out that the federal court did not have a license to disregards the findings that were uncovered during the state administrative findings. Hence, the federal court’s decision was invalid and could not apply in the case. However, the Appellate Court affirmed the ruling of the local hearing and review officers. The final ruling supported Mark’s IEP team’s proposal to place him in a self-contained classroom where he would receive beneficial education.
Reasoning
In the final ruling, the court denied Mark’s parents’ request that the student should remain in a general education classroom. The IDEA’s mainstreaming presumption provides that “disabled children are to be educated with non-disabled children only to the maximum extent appropriate” (Stone, 2019). The court used the DeVries v. Fairfax County School Board to determine whether mainstreaming was necessary for Mark’s situation. The case provides three conditions when inclusion is not required. One is when a student with disabilities will not obtain any educational benefit if placed in a general education classroom. The second condition is if the benefits that a student gets from a separate instructional setting would outweigh any marginal benefit they derive from mainstreaming. The third condition is if “the child is a disruptive force in the general education classroom” (Katsiyannis & Herbst, 2004). The appellate court determined that Mark met the above three conditions and did not qualify to be in a general classroom with other students.
Implications for Policy
The court’s ruling has various legal implications in the education sector. One is that public schools that educate disabled children should explore multiple alternatives for a child with disabilities before placing them in a regular classroom (Stone, 2019). Teachers should ensure that they try to provide specialized education to students before placing them in specialized education systems. From then, they should provide their professional opinion. A school should evaluate whether the student benefits more from being in a general education program or a self-contained setting. Another legal implication is about the federal court’s position to rule over cases of the least restrictive environment. Despite IDEA’s presumption on mainstreaming, the federal court is not licensed to disapprove findings established in state administrative proceedings. The court does not also have the license to suggest its views of sound educational policy on behalf of local school authorities ( Hartmann v. Loudoun County Board of Education , 1997). Another implication is that districts must ensure that students study in the least restrictive environment. Schools should not discriminate against students with disabilities in any way possible but must ensure that disabled children study with their peers to the maximum extent possible and appropriate (Stone, 2019). In the end, schools will avoid any legal liabilities associated with the discrimination of disabled students.
References
DeVries v. Fairfax County School Bd ., 674 F. Supp. 1219 (E.D. Va. 1987).
Hartmann v. Loudoun County Board of Education , 118 F.3d 996 (4th Cir. 1997).
Katsiyannis, A., & Herbst, M. A. R. I. A. (2004). Minimize litigation in special education. Intervention in School and Clinic , 40 (2), 106-110.
Stone, D. H. (2019). The Least Restrictive Environment for Providing Education, Treatment, and Community Services for Persons with Disabilities: Rethinking the Concept. Touro L. Rev. , 35 , 523.
