More than twenty years ago, the Individuals with Disabilities Education Act (IDEA) promised disabled children they would receive a "free appropriate public education" in regular classrooms with non-disabled children whenever possible-a minimally adequate education and access to an integrated school setting. The Supreme Court undermined the first half of that promise in 1982, interpreting an "appropriate" or minimally adequate education primarily as one that is reasonably calculated to confer "some educational benefit." It is a standard even the poorest classroom arguably meets.

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