Pennsylvania Association for Retarded Children v. Commonwealth of Pennsylvania

343 F. Supp. 279 (1972)

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Pennsylvania Association for Retarded Children v. Commonwealth of Pennsylvania

United States District Court for the Eastern District of Pennsylvania
343 F. Supp. 279 (1972)

  • Written by Alexander Hager-DeMyer, JD

Facts

The State of Pennsylvania (state) (defendant) enacted statutes that (1) relieved the state board of education of its obligation to educate children whom a public school psychologist found uneducable, (2) allowed indefinite postponement of public-school admission for children who had not attained a mental age of five, (3) excused children from compulsory school attendance if a psychologist found the children unable to profit from education, and (4) made school mandatory until age 17. The last factor was used to exclude disabled children from school after the age of 17 regardless of developmental status. The Pennsylvania Association for Retarded Children (plaintiff) and 13 individual students (plaintiffs) filed a class-action suit against the state and its school districts on behalf of all mentally disabled students who were excluded from public school education programs. The students claimed that the statutes were unconstitutional on due-process and equal-protection grounds, arguing that the statutes did not provide due-process hearings before denying students access to public education or altering their educational placements and that the statutes were based on the unfounded premise that certain disabled students were uneducable. Expert testimony established that all mentally disabled persons were capable of benefiting from education. Lastly, the students argued that because the United States Constitution and state laws guaranteed educations to all children, statutes that denied that right to disabled children were also unconstitutional on due-process grounds. The parties met to settle the matter and submitted a consent agreement to the district court for approval. Under the agreement, the statutes could not be used to deny a mentally disabled child of his right to an education. The state was required to provide each disabled child with a free and appropriate public education, and disabled children’s educational placements were to be reevaluated every two years. Additionally, hearings were to be offered before any adjustment to a disabled child’s educational status. The court reviewed the order for fairness and reasonableness to both parties and approved the measures as having cured the due-process and equal-protection concerns.

Rule of Law

Issue

Holding and Reasoning (Masterson, J.)

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