Sacramento City Unified School District v. Rachel H.

Rachel Holland (plaintiff) was a student in the Sacramento Unified School District (the district) (defendant). Holland was mentally handicapped with an intelligence quotient (IQ) of 44 as an 11-year-old. Holland attended a variety of special-education programs in the district from 1985 to 1989. Holland’s parents then requested that Holland be placed full-time into a regular classroom for her kindergarten year. The district rejected this request and offered a placement that divided her educational time between a special-education classroom and a regular-education classroom. This proposal would have required Holland to be moved six times each day between the two classrooms. Holland’s parents appealed this decision and enrolled Holland in a private school. In the private school, Holland was placed into a regular-education classroom, where she performed well and did not cause a disruption or require significant amounts of the teacher’s attention. The initial appeal of the placement was heard by a state hearing officer under the Individuals with Disabilities Education Act (IDEA). The hearing officer determined that the district should have placed Holland in a regular-education classroom full-time. The district appealed to district court, which affirmed. The district court gave significant weight to the testimony of Holland’s private school teacher, who said that Holland was making progress toward her individualized-education plan (IEP) goals in her regular-education classroom. The district then appealed to the United States Court of Appeals for the Ninth Circuit.