During the early 1980s, public schools were still adapting to the requirements of the Education for All Handicapped Children Act (EAHCA) of 1975, which mandated a Free Appropriate Public Education (FAPE) for students with disabilities. However, many school districts were resistant to serving students whose disabilities manifested in behavioral challenges or disciplinary issues.

Garrett vs. Board of Education of the School District of Detroit (1983) centered on a student with a disability whose behavioral problems led the school district to deny him special education services. The district argued that his conduct issues disqualified him from receiving services. The court ultimately ruled that students with disabilities cannot be denied special education and related services based on behavior problems, especially when those behaviors are related to their disabilities. This case was pivotal because it affirmed that discipline issues do not negate a student’s right to appropriate educational services. 

This case had significant effects on the lives of students with disabilities, families, schools, and society as a whole. It reinforced students’ rights to remain in school and receive services, even when they exhibit difficult or disruptive behavior due to their disability. For families, it empowered them to advocate for behavioral and emotional support services as part of their child’s Individualized Education Program (IEP). In schools and society, it challenged the tendency to exclude or punish students with disabilities without addressing the root cause. This root cause was (and still is) often a lack of proper support. It helped shift the conversation toward inclusion and understanding, rather than exclusion and punishment. The ruling influenced broader attitudes toward disability rights, reinforcing that equity in education includes students with emotional and behavioral disabilities.

Garrett vs. Board of Education of the School District of Detroit (1983) laid groundwork for future legal protections by establishing that behavioral issues cannot be used as a reason to exclude students from special education, especially when those behaviors are related to their disability. It also laid the groundwork for the need for schools to implement behavioral interventions and support plans as part of FAPE.

This case also helped set the stage for Honig v. Doe (1988), a U.S. Supreme Court case that built upon the principles in this case, ruling that students with disabilities cannot be expelled for behavior related to their disability without proper due process. It also helped get the ball rolling on the growing emphasis on Functional Behavioral Assessments (FBAs) and Behavior Intervention Plans (BIPs), later required under amendments to IDEA in the decades following.

This timeline outlines this specific case, as well as other prominent cases in the world of special education law.