Inclusion, the philosophy of placing all children with disabilities in regular education settings, is easily the most discussed and controversial education reform issue since the 1975 passage of PL 94-142, Education of Handicapped Children Act (EHA). However, inclusion is never mentioned in the original EHA or the updated PL 101-476, Individuals with Disabilities Education Act (IDEA) (e.g., Sherrill, 1994; Stein, 1994). What is discussed in IDEA as well as Section 504 of the Rehabilitation Act of 1973 is the “continuum of least restrictive environments” (LRE). The purpose of this paper is to (a) review United States federal laws regarding inclusion and LRE, most notably IDEA and Section 504 of the Rehabilitation Act of 1973; (b) review recent U.S. court cases regarding inclusion and LRE including three landmark cases: Roncker v. Walter (Ohio) (1983), Daniel R.R. v. State Board of Education (Texas) (1989), and Sacramento Unified School District, Board of Education v. Rachel H. (California) (1994); and (c) apply these federal laws and court decisions to physical education placement.
Martin E. Block is with the Program Area of Health and Physical Education, Memorial Gymnasium, University of Virginia, Charlottesville, VA 22903.