The Mainstreaming Cases: Tensions and Trends for School Administrators

Abstract

Educational administrators may sometimes feel caught between the special education requirements of a free appropriate public education and the preference for mainstreaming embodied in federal special education law. Understanding decisions from the U.S. Court of Appeals can help school administrators determine how to balance the two requirements. Analysis of circuit court decisions reveals four overlapping judicial standards, depending, among other things, on whether physical and social mainstreaming or instructional mainstreaming is at stake. Many of the circuit opinions have introduced cost as a legitimate factor in placement decisions while ignoring some of the least restrictive environment regulations. Although circuit courts are not ordering education agencies to provide highly specialized services in each neighborhood school, a number of courts are requiring schools to make reasonable efforts to deliver special instruction in mainstream classrooms. School administrators are advised not to adopt either a blanket separation model ora blanket 'full inclusion" model of service delivery for all students with severe disabilities but to continue to make individualized placement decisions that honor the concept of least restrictive environment.