## Facts

- Rachel H., an elementary-aged child with an intellectual disability (IQ 44), had attended various special education programs in the Sacramento City Unified School District.
- For the 1989–1990 school year, Rachel’s parents requested full-time placement in a regular second-grade classroom.
- The District refused full-time mainstreaming and proposed a split program: special education for academic subjects and a regular classroom for nonacademic activities (e.g., art, music, lunch, recess), requiring multiple daily classroom transitions.
- Rachel’s parents rejected the proposed split placement and enrolled her in a private school where she attended a regular classroom full-time.
- Evidence from the private placement indicated Rachel made progress toward IEP goals, received academic benefit, and gained social/communication benefits from interaction with nondisabled peers, without significant disruption.
- A state administrative hearing officer found the District failed to adequately consider education in a regular classroom and ordered full-time regular classroom placement with supplemental aids and services.
- The federal district court, after an evidentiary hearing, affirmed the administrative decision; the District appealed.

## Issues

1. Whether the IDEA’s least restrictive environment (LRE) requirement mandated full-time placement in a regular classroom with supplemental aids and services rather than the District’s proposed split placement.
2. What factors govern whether a regular classroom placement is appropriate under the IDEA’s mainstreaming mandate.

## Decision

- The Ninth Circuit affirmed the district court’s judgment upholding the administrative order.
- The court held that Rachel’s appropriate placement under the IDEA was full-time in a regular classroom with supplemental aids and services.
- The court upheld factual findings that Rachel obtained meaningful educational and nonacademic benefits in a regular classroom and did not materially impair the education of others.
- The court rejected the District’s cost objection because the District did not show mainstreaming costs were prohibitive or would materially impair services to other students.

## Legal Principles

- The IDEA requires education with nondisabled peers to the maximum extent appropriate; removal to separate classes is permitted only when education in regular classes with supplementary aids and services cannot be satisfactorily achieved.
- In assessing whether full-time regular classroom placement is appropriate under the LRE mandate, courts consider:
  - the educational benefits of regular-class placement with supports compared to segregated settings;
  - the nonacademic benefits of interaction with nondisabled peers;
  - the effect of the student’s presence on the teacher and other students (including disruption and demands on teacher time); and
  - the cost of mainstreaming (relevant but not controlling absent prohibitive expense or material impact on other students’ services).
- In IDEA placement disputes, a reviewing court makes an independent decision based on the preponderance of the evidence while giving due weight to state administrative proceedings.

## Conclusion

Applying the LRE factors, the Ninth Circuit concluded that full-time placement in a regular classroom with supplemental aids and services satisfied the IDEA because Rachel received meaningful academic and social benefits, did not significantly disrupt the classroom, and the District failed to prove that the added costs made mainstreaming inappropriate.


Sacramento City Unified Sch. Dist. Bd. of Educ. v. Rachel H., 14 F.3d 1398 (9th Cir. 1994)