This case involved Rachel Holland, a child with moderate mental retardation who was denied full-time placement in general education by the Sacramento City School District. The court ruled that Rachel's appropriate placement under IDEA was in general education with supplemental supports. The district did not prove that the additional costs of educating Rachel in general education were too burdensome. The court ordered Rachel be placed in a general education second grade class. This established that academic benefit is not required for inclusion and that districts must incur additional costs to provide placement in the least restrictive environment.

1. Board of Education, Sacramento City
School District v. Rachel Holland:
Making the Case for Full Inclusion
Sherwood Best, Ph.D.
Professor
CSULA
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2. Board of Education, Sacramento
City School District
v.
Rachel Holland
786 F. Supp. 874 (E.D. Cal.1992)
Argued December 16, 1991
Decided March 2, 1992
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3. Background
 Rachel was a young child with an IQ of
44 & developmental level of 4 years.
She attended private preschool at the
Shalom School.
 From 1985-1989, Rachel attended a
number of special education programs
in the Sacramento City School District.
 From 1987-1987 she spent 1 hour a
day in a general education class.
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4. Background
 In 1989, the Hollands requested full-
time placement in general education.
The District countered with a special
education placement.
 The Hollands sought mediation and
the District then offered special
education placement with up to ½
time in general education.
 The Hollands rejected the District’s
offer and re-enrolled Rachel in the
Shalom School’s Kindergarten class.
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5. Background
 Through another mediation the
Hollands & the District agreed to an
IEP. Meanwhile, the Hollands appealed
the District’s decision to a state
hearing officer.
 On August 15, 1990, the hearing
officer made a report stating that the
District had made insufficient effort to
include Rachel in general education.
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6. Background
 The hearing officer ordered the District
to place Rachel in general education
with appropriate support services.
 The District appealed the decision to
state district court. The Hollands kept
Rachel in Shalom School.
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7. Issues
 Is full-time placement in general education
appropriate for a child with moderate mental
retardation?
 The interpretation of the hearing officer that
“appropriate education” meant education in
general education for Rachel.
 Whether the district was overburdened with
cost and administrative duties in providing
for Rachel in general education.
 Is the burden of educating children like
Rachel too difficult for the general education
teacher?
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8. Applicable Law
 IDEA, which states that, “to the
maximum extend appropriate,
handicapped children shall be
educated with their non-
handicapped peers.” (20 U.S.C.,
sec. 1400-1485).
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9. Argument Base
 Both plaintiffs & defendants based
their arguments around 4 points:
 Are Rachel’s disabilities so severe that she would
receive little or no academic benefit from
placement in general education?
 Are Rachel’s disabilities so severe that she would
receive little of no non-academic benefit from
placement in general education?
 Does Rachel have a negative effect on other
children in the general education placement?
 Is the cost of educating Rachel in general
education too burdensome for the district?
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10. Arguments - Plaintiffs
 The plaintiffs argued as follows:
 Rachel had made no progress toward her IEP
goals, which were based on functional skills
(handling money, performing activities of
daily living, transportation, etc.).
 Rachel was isolated and not learning from
her classmates.
 The cost of educating Rachel in general
education would be too high for the district,
as she required several services (like speech)
that she would need to receive in general
education.
 Rachel would take up too much of the
general education teacher’s time. 10

11. Arguments - Defendants
 The defendants argued as follows:
 Rachel had made significant progress at
Shalom School, where she was learning
language and social skills from her peers
 The standardized tests used to measure
Rachel’s progress were not a useful
measure of her achievement.
 Rachel could easily be accommodated in
general education with “supplemental
supports & services”, as stipulated by
IDEA.
 Rachel was an agreeable & compliant child
who posed no disruptive threat to her
classmates.
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12. Holding
 The appropriate placement for Rachel
Holland, under IDEA, was general education.
 The district had not met a burden of proof
related to the extra expense of education
Rachel in general education.
 Rachel was making both academic and
nonacademic progress in general education
 Rachel was no burden on other children in
general education.
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13. Dicta
 The district may be required to incur
additional cost as a result of a child’s
placement into general education.
 Academic benefit is not a necessary
condition for continued placement in
general education.
 Curriculum modifications may be
cumbersome for teachers not trained to
meet the needs of children like Rachel.
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14. Court’s Orders
 Rachel Holland was placed into a
general education second grade
class with supplemental supports
and services.
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15. Implications for Special Education
 Funding, administrative burden &
attitude are not sufficient conditions to
deny inclusion.
 More children will be included in
general education classes.
 School districts will make varying
efforts to train teachers to assist
included children.
 More litigation!!
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