Hartmann v. Loudoun County Board of Education et al. HANNAH MORMANDO LILIANNA BERMEJO

Facts  Plaintiff: Mark Hartmann (child) and parents Roxanna and Joseph Hartmann  Defendant: Loudoun County Board of Education  Characteristics of Mark Hartmann:  11 years old  ASD  Limited communication skills  Problem behaviors

Issues  Placement  Where should Mark be educated? In a general or special education classroom?  Qualifications  Were the teachers and professionals working with Mark adequately qualified?

Statutory and Case Law Individuals with Disabilities Education Act (IDEA)  Mainstreaming Provision DeVries v. Fairfax County School Board  Three conditions where the mainstreaming provision is inappropriate Board of Education of Hendrick Hudson Central School District v. Rowley

Findings and Orders District Court’s Findings:  Rejected administrative findings and concluded that Mark could receive significant educational benefit in a regular classroom. Loudoun County did not take enough appropriate steps to include Mark in a gen ed classroom. Appellate Court’s Finding  Reversed and remanded District Court’s ruling, claiming that based on administrative findings, Mark was not making academic progress in the general education classroom despite the aids and services provided. Additionally, Loudon County properly proposed an IEP placing Mark in a self- contained classroom where he could receive an beneficial education.

Application to Current Practice  “IDEA does not grant federal courts a license to substitute their own notions of sound educational policy for those of local school authorities, or to disregard the findings developed in state administrative proceedings” (Hartmann v. Loudoun County Board of Education, 1997)