## Facts

- Rachel Holland, a nine-year-old student with an intellectual disability (IQ 44), functioned academically at about a four-year-old level but was well-behaved, socially accepted by peers, and motivated to learn.
- From 1985–1989, the school district placed Rachel mainly in special education and provided limited integration in regular classes (about one hour per day).
- For the 1989–1990 school year, Rachel’s parents requested full-time placement in a regular classroom; the district offered an IEP with half-day special education and half-day regular education.
- The parties agreed on IEP goals but not placement; the parents rejected the proposed placement and enrolled Rachel in a private regular-education kindergarten class with a part-time aide.
- After a fourteen-day administrative hearing under the IDEA, a hearing officer ordered the district to place Rachel full-time in a regular classroom with specified supplementary aids and services.
- The district filed a federal action challenging the administrative order, arguing that full-time regular-class placement was not appropriate for Rachel.

## Issues

1. Whether the IDEA’s least restrictive environment requirement mandated Rachel’s full-time placement in a regular classroom with supplementary aids and services, rather than a split placement with significant time in a special-education classroom.
2. How to evaluate “appropriate” placement under the IDEA when academic test scores suggest limited progress but evidence shows functional and social gains in a regular classroom.
3. Whether the effect on the regular classroom (disruption, diversion of teacher time) and the cost of supports justified a more restrictive placement.

## Decision

- The court affirmed the hearing officer’s decision requiring full-time placement in a regular classroom with supplementary aids and services.
- The court held the district failed to show that education in a regular class with supports could not be achieved satisfactorily.
- The court rejected the district’s reliance on standardized testing as dispositive, crediting teacher testimony and qualitative evidence of benefit in the regular classroom.
- The court found Rachel’s inclusion did not materially disrupt instruction for other students and that the needed supports were not so costly as to justify removal from the regular environment.

## Legal Principles

- Under the IDEA, children with disabilities must be educated with non-disabled peers to the maximum extent appropriate; removal from the regular environment is permitted only when satisfactory education in regular classes with supplementary aids and services cannot be achieved.
- Judicial review of an IDEA administrative decision requires an independent determination based on the preponderance of the evidence while giving due weight to the administrative findings.
- In evaluating least restrictive environment compliance, courts consider: (1) educational benefit in regular class with supports compared to special class, (2) nonacademic benefits of interaction with non-disabled peers, (3) effect on the teacher and other students, and (4) cost of mainstreaming.

## Conclusion

The court upheld full-time inclusion because the record showed Rachel received meaningful educational and nonacademic benefits in the regular classroom with supports, without undue disruption or prohibitive cost, making that setting the least restrictive environment appropriate under the IDEA.


Bd. of Educ., Sacramento City Unified Sch. Dist. v. Holland, 786 F. Supp. 874 (E.D. Cal. 1992)