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Garrett v. Board of Education of the School District of Detroit (1983) was a landmark case that addressed the rights of students with disabilities to receive appropriate educational services, even if they had disciplinary issues. Prior to this case, students with disabilities were often excluded from educational services if their behavior was deemed disruptive. This case arose from the conflict between the need for appropriate educational accommodations and the school’s authority to enforce discipline.

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Historical Context and Significance Continued

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Historical Context and Significance Continued

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The context of the case: In the 1970s and 1980s, there was growing awareness of the need to provide students with disabilities a free and appropriate public education (FAPE), as mandated by the Education for All Handicapped Children Act (EAHCA), which later became IDEA (Individuals with Disabilities Education Act).

The dispute: The student in this case had behavior problems and was facing suspension or expulsion. The case examined whether the school district had to provide services to the student despite these behavioral issues.

The outcome: The court ruled that schools must continue to provide appropriate educational services to students with disabilities, even if they have disciplinary problems, under the provisions of EAHCA.

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This case had profound social implications, particularly in how society viewed the intersection of disabilities and education.

Impact on students: It helped ensure that students with disabilities, including those with behavioral issues, were not excluded from education. The ruling reinforced the importance of providing accommodations and continuing educational support.

Impact on families: Families of students with disabilities were empowered by the legal acknowledgment of their children's right to appropriate education, regardless of disciplinary concerns.

Impact on society: It contributed to the shift in societal attitudes towards the inclusion of people with disabilities, promoting a more inclusive, supportive, and equitable educational system.

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The Garrett case set a critical legal precedent for the future of special education law:

FAPE requirements: The ruling reinforced that students with disabilities are entitled to a free and appropriate public education, even if they face behavioral challenges.

Special education litigation: It shaped future litigation regarding how schools must accommodate students with disabilities, ensuring they receive support in both academic and behavioral contexts.

Influence on IDEA: The case aligned with the goals of IDEA, helping to refine the understanding of the act’s provisions regarding student behavior and the continuance of educational services.

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1975 – Education for All Handicapped Children Act (EAHCA) Passed

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1975 – Education for All Handicapped Children Act (EAHCA) Passed

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Description:
Congress passes the Education for All Handicapped Children Act (EAHCA), requiring public schools to provide a "free and appropriate public education" (FAPE) to all students with disabilities. The creation of FAPE increases the enrollment rates of students with a disability into schools immensely.
Significance:
This law lays the foundation for all future special education rights, including those addressed in Garrett v. Board of Education.

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1983 – Garrett v. Board of Education of the School District of Detroit

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1983 – Garrett v. Board of Education of the School District of Detroit

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Court Case Summary:
This pivotal case addressed whether students with disabilities could be denied services due to behavioral issues. The student involved had significant behavior problems and faced removal from school.
Court Ruling:
The court ruled that a student with a disability must still receive appropriate educational services, even when facing disciplinary actions. Regardless of their behavior, every child deserves the fair equal and opportunity to education and their accommodations regardless of behavioral issues.
Significance:
Confirmed that behavior does not disqualify a student from their legal right to a FAPE under EAHCA.

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1990 – EAHCA Becomes IDEA (Individuals with Disabilities Education Act)

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1990 – EAHCA Becomes IDEA (Individuals with Disabilities Education Act)

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Description:
EAHCA is reauthorized and renamed IDEA. This update includes more robust protections, especially regarding disciplinary procedures and educational access for students with behavioral challenges.
Significance:
Garrett’s case helped influence this change in many different ways. The most important one we chose to highlight was the fact that there was a crucial need to protect students with disabilities, especially students who had behavioral problems and were losing access to education due to something in which was out of their control.

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1997 – IDEA Amendments Emphasize Discipline Protections

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1997 – IDEA Amendments Emphasize Discipline Protections

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Description:
IDEA stands for Individuals with Disabilities Act. IDEA is amended to include specific procedures for disciplining students with disabilities. Schools must determine whether a student’s behavior is linked to their disability before taking disciplinary action.
Significance:
These changes reflect the legal principles affirmed in Garrett v. Board of Education, reinforcing the right to continued educational access.

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Garrett v. Board of Education (1983) reinforced that students with disabilities cannot be denied their right to education due to behavior, socioeconomic status, or the accommodations that the student needs. This case had a lasting impact on how schools discipline and support students with disabilities. It helped lay the groundwork for IDEA’s protections and remains crucial for educators to understand when working with students who require both academic and behavioral support.

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Garrett V. Board of Education Reflective Summary