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I believe that the change of practice that we see from this is the intense study of where the best environment is for the student with disabilities. Both least and most restrictive environments have their positives and negatives but in the end it really depends on the student.

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I believe it was hard for Mark’s family to see him taken out of a mainstream classroom because they were focused on him and his development. They had a different perspective than that of the school officials.

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In this case it showed that the school really did a lot for Mark. They not only wanted the best for him but for the other students in the class.

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My impression of this case was that I thought it was surprising. Most of the time when we hear about a case involving a school and a student with a disability I know in my mind that usually the school is at fault for not doing enough for the student.

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I also believe that it is important for families to learn from this as the district court’s ruling was overruled by the fourth circuit. Sometimes you really have to fight, granted this did not end in the way Mark’s family wanted it to but it ended with an answer

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I believe that this might help future families realize that what seems like the best option might not always be the best option. I read this case multiple times and I really had to look from both points of view. The family and the school were both fighting to help Mark but from different perspectives.

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This case is significant because it shows that sometimes the least restrictive environment is not the best environment for the student to learn or develop in. IDEA clearly favors integration but realizes that some more restrictive environments can be more appropriate to some students. This also helps show that all cases are different and what might work for one student might not work for another one.

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Significance

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“IDEA does not grant federal courts a license to substitute their own notions of sound educational policy for those of local school authorities, or to disregard the findings developed in state administrative proceedings”(Worrell, 1998)

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The Fourth Circuit realized that IDEA requires disabled children to be educated along with non-handicapped children "to the maximum extent appropriate" but it does not require a county to provide "every special service necessary to maximize each handicapped child's potential."

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It would be economically unfeasible and equally unrealistic to expect every school system to have the highest accredited educators. Using this reasoning, the Fourth Circuit dismissed the district court's conclusions that county efforts were insufficient to educate Mark in the regular classroom due to inadequately trained personnel (wrightslaw.com,1998)

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The courts argued that the school equipped Mark with unqualified educators to help him succeed.

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The courts argued that the school equipped Mark with unqualified educators to help him succeed.

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The local hearing officer after hearing all that the school had done to help Mark sided that the Board had done enough. According to the Board they had supplied Mark with professional educators that were willing and qualified to help him succeed.

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This courts decision was overturned by a higher court.

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The district court ignored the precedent of DeVries v. Fairfax County School board in which it was stated that mainstreaming was not required where

·         The student with a disability would not receive an educational benefit from mainstreaming

·         The student is a disruptive force in a regular setting

·         Any marginal benefit from mainstreaming would be significantly outweighed by benefits which could feasibly be obtained only in a separate instructional setting

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Education and the Law,84-85. (2010). Retrieved from https://www.tandfonline.com/doi/abs/10.1080/10459889909603307?journalCode=vpsf20

Mark Hartmann v. Loudoun Co. Sch. Bd., 118 F.3d. 996 (4th Cir. 1997), cert. denied, 118 S. Ct. 688 (1998). (n.d.). Retrieved from http://www.wrightslaw.com/law/caselaw/case_Hartmann4thCir.html

Worrell, A. L. (n.d.). Courts Must Consider State Administrative Findings in Determining Educational Placement of Disabled Children. Retrieved September 20, 2018, from https://lawecommons.luc.edu/cgi/viewcontent.cgi?article=1409&context=lclr

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Joseph and Roxana Hartmann Today Show Interview

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The district court stated that "given the strong presumption for inclusion under the IDEA, disruptive behavior should not be a significant factor in determining the appropriate educational placement for a disabled child"(Worrell, 1998).

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The district court attributed Mark’s lack of progress in Loudoun County to the county’s alleged failure to make reasonable efforts to accommodate him in the regular classroom.

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Mark Hartmann was an 11-year old who had autism and disruptive behavior. His IEP team found that he was making no academic progress in the regular classroom and proposed moving him to a smaller class specifically structured for students who had autism. His parents argued that his placement would violate IDEA's Least Restrictive Environment.