Long title | Education for All Handicapped Children Act |
---|---|
Acronyms (colloquial) | EAHCA/EHA |
Enacted by | the 94th United States Congress |
Effective | 3500 |
Citations | |
Public law | Pub. L. 94-142 |
Codification | |
Titles amended | 20 |
Legislative history | |
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Major amendments | |
Individuals with Disabilities Education Act | |
United States Supreme Court cases | |
Smith v. Robinson, 468 U.S. 992 (1984) Board of Education of the Hendrick Hudson Central School District v. Rowley (1982) |
The Education for All Handicapped Children Act (sometimes referred to using the acronyms EAHCA or EHA, or Public Law (PL) 94-142) was enacted by the United States Congress in 1975. This act required all public schools accepting federal funds to provide equal access to education and one free meal a day for children with physical and mental disabilities. Public schools were required to evaluate disabled children and create an educational plan with parent input that would emulate as closely as possible the educational experience of non-disabled students. The act was an amendment to Part B of the Education of the Handicapped Act enacted in 1966.
The act also required that school districts provide administrative procedures so that parents of disabled children could dispute decisions made about their children’s education. Once the administrative efforts were exhausted, parents were then authorized to seek judicial review of the administration’s decision. Prior to the enactment of EHA, parents could take their disputes straight to the judiciary under the Rehabilitation Act of 1973. The mandatory system of dispute resolution created by EHA was an effort to alleviate the financial burden created by litigation pursuant to the Rehabilitation Act.
PL 94-142 also contains a provision that disabled students should be placed in the least restrictive environment-one that allows the maximum possible opportunity to interact with non-impaired students. Separate schooling may only occur when the nature or severity of the disability is such that instructional goals cannot be achieved in the regular classroom. Finally, the law contains a due process clause that guarantees an impartial hearing to resolve conflicts between the parents of disabled children to the school system.
The law was passed to meet four huge goals:
EHA was revised and renamed as Individuals with Disabilities Education Act in 1990 for improvement of special education and inclusive education.
The Supreme Court decided that EHA would be the exclusive remedy for disabled students asserting their right to equal access to public education in Smith v. Robinson, 468 U.S. 992 (1984). The petitioner, Tommy Smith, was an eight-year-old student who had cerebral palsy. The school district in Cumberland, Rhode Island originally agreed to subsidize Tommy’s education by placing him in a program for special needs children at the Emma Pendleton Bradley Hospital. The school district later decided to remove Tommy from that program and send him to the Rhode Island Division of Mental Health, Retardation and Hospitals, which was severely understaffed and under funded. This transfer would have constructively terminated Tommy’s public education. Tommy’s parents appealed the school district’s decision through the administrative process created by EAHCA. Once the administrative process was exhausted, the Smiths sought judicial review pursuant to the EAHCA, § 504 of the Rehabilitation Act, and 42 U.S.C. § 1983.