Board of Education, Sacramento City Unified School District v. Holland

Rachel Holland (defendant) was moderately mentally retarded. From 1985 until 1989, Rachel was educated in special-education programs within the Sacramento City Unified School District (defendant). During half of that time, Rachel attended a regular class for no more than one hour per day, although her parents pushed for more. For the 1989–1990 school year, Mr. and Mrs. Holland requested that Rachel be placed in a regular class full time. Instead, the district recommended that Rachel’s individualized-education program (IEP) consist of placement in a regular class for nonacademic subjects and in a special-education class for academic subjects. The Hollands rejected that IEP and enrolled Rachel in a regular kindergarten class at a private school, where she was assisted by a part-time aide. Meanwhile, the Hollands disputed the placement decision. Following mediation, the Hollands agreed to the language and communication goals of Rachel’s IEP but still disputed her placement. Pursuant to the Individuals with Disabilities Education Act (IDEA), the Hollands appealed the decision to a state hearing officer, who found in their favor. The board appealed the decision to a United States district court. To support its case, the district provided evidence of Rachel’s performance on achievement and aptitude tests, which were conducted at a state diagnostic center by two test administrators who concluded that Rachel had not made progress on her IEP goals. Two teachers from the private school that Rachel still attended served as witnesses for the Hollands. Particularly, Rachel’s second-grade teacher provided that Rachel was independent, self-confident, and eager to learn as most second-graders. Further, Rachel’s accommodations did not burden the classroom, and although Rachel was two years older than most of her classmates, she was not treated any differently.