## Facts

- Mark Hartmann, an eleven-year-old student with autism, had severe communication and motor impairments, was nonverbal, and could type only a few words consistently.
- In second grade, he was placed in a regular education classroom with extensive supports, including a reduced class size, a full-time one-on-one aide, speech-language services, and special education consultation and instruction.
- The IEP team concluded Mark made no meaningful academic progress in the regular classroom and engaged in frequent disruptive behaviors (including screeching, hitting, biting, and disrobing) that interfered with instruction.
- The school district proposed a new IEP placing Mark in a self-contained autism class at Leesburg Elementary, with mainstreaming for certain nonacademic activities (e.g., lunch and recess).
- Mark’s parents rejected the proposed placement and sought full-time placement in a regular classroom with supplementary aids and services.
- A local hearing officer and a state review officer upheld the district’s proposed IEP and placement.
- The federal district court reversed, finding full-time inclusion appropriate and concluding the district had not provided sufficient supports.
- The school board appealed.

## Issues

1. Whether the district court failed to give due weight to the administrative findings and improperly substituted its educational judgment for that of educators and hearing officers under IDEA.
2. Whether the proposed IEP satisfied IDEA’s least restrictive environment requirement by educating Mark with nondisabled peers to the maximum extent appropriate.
3. Whether Mark’s lack of academic progress and disruptive behavior justified placement outside the regular classroom despite substantial supplementary aids and services.

## Decision

- The Fourth Circuit reversed the district court and remanded with instructions to dismiss the complaint.
- The court held the school board’s IEP complied with IDEA by offering an educational program reasonably calculated to provide educational benefit.
- The court held the district court erred by discounting administrative findings and effectively conducting de novo review of educational policy and methodology.
- The court concluded that, given the record of minimal progress and significant disruption despite extensive supports, a self-contained autism class with partial mainstreaming satisfied IDEA’s mainstreaming mandate.

## Legal Principles

- Courts reviewing IDEA placement disputes must give due weight to state administrative proceedings and may not substitute judicial preferences for educators’ judgments about educational policy, placement, and methodology.
- IDEA requires an IEP reasonably calculated to confer some educational benefit, not to maximize a child’s potential.
- The least restrictive environment requirement is qualified: a child must be educated with nondisabled peers only to the maximum extent appropriate, considering educational benefit, classroom impact, and the effectiveness of supplementary aids and services.
- Persistent disruptive behavior and lack of academic progress, even after substantial supports, may support a more restrictive placement consistent with IDEA.

## Conclusion

The Fourth Circuit upheld a self-contained autism placement with partial mainstreaming, emphasizing that IDEA does not require full-time inclusion when a student receives little academic benefit and significantly disrupts the classroom despite extensive supports, and that courts must defer to administrative and educator determinations when supported by the record.


Hartmann v. Loudoun Cnty. Bd. of Educ., 118 F.3d 996 (4th Cir. 1997)