Armstrong v. Kline (1979)
- Sam Shepherd
- Jan 27
- 3 min read
By Davina Haggar
Overview
In Armstrong v. Kline (1979), the U.S. District Court and the U.S. Court of Appeals for the Third Circuit addressed the needs of extending school years for students with severe disabilities. The plaintiffs claimed that the Education for All Handicapped Children Act of 1975 (EAHCA) had been violated by the state of Pennsylvania, after being denied an extended school year. This case reinforced that under EAHCA, disabled children receive free public education with tailored programs to meet their needs, which can include extending the academic calendar beyond the standard number of instructional days (Justia US Law). The plaintiffs argued that under this act, disabled children must be provided with free public education to satisfy their needs, even if that entails extending instruction beyond the average 180 days. They claimed that their children struggled with regression during long breaks, like summer, often forgetting skills learned at school, making relearning topics more challenging.
Summary
In January 1978, the parents of five disabled students filed lawsuits against the defendant, John Kline, the former Secretary of Education of Pennsylvania. The plaintiffs, the parents of five severely disabled students, argued that the Pennsyalvania’s 180-day school year policy infringed on EAHCA. This act entitled disabled children with free public education and programs to fit their needs (U.S. Government Accountability Office). The plaintiffs argued that their children's right to free public education with tailored programs was violated when their request to extend the school year beyond 180 instructional days was denied. They claimed that their children’s skills deteriorated during long breaks, forcing them to relearn lost skills, preventing them from keeping up with new instruction.
The state of Pennsylvania disagreed with the plaintiffs argument, claiming that these children could easily regain the skills they lost during breaks. This case then proceeded to the federal district after Pennsylvania denied the parent’s claims. The plaintiffs provided evidence supporting the claim that disabled students had a difficult time recouping the skills they learned in school, concluding that the standard 180 days of instruction does not meet their children's demands. While the EAHCA did not explicitly mention the requirement to extend the academic school year, the ruling of Armstrong vs. Kline established that the Free Appropriate Public Education (FAPE) could result in an extended school year to ensure the needs of disabled children are met to prevent them from losing what they learned.
The case was first introduced to the U.S. District Court for the Eastern District of Pennsylvania, where they ruled in favor of the plaintiffs. They concluded that the 180-day instruction limit failed to meet the needs of disabled children, violating FAPE under the EAHCA. Even if the school needed to extend the 180 days of instruction per year, the state is required to adjust to meet the needs of disabled children.
The state of Pennsylvania appealed the District Court’s decision and the U.S. Court of Appeals upheld the District Court’s ruling. The appellate court claimed that the time it took for disabled children to regain the skills they lost over long breaks might prevent them from properly continuing their education after returning to school, therefore granting disabled children the right to Extended School Year (ESY), services that disabled students are provided with during extended breaks (California Association of Health and Education).
Impact
This case established ESY as a significant component to FAPE for students with disabilities to avoid losing essential skills, even if that means extending the school year instruction and teaching over long breaks. Since many disabled students regress their skills over prolonged periods of time, it has a significant impact on their education and impedes the children’s ability to make progress.
Court documents
Citations
“Extended School Year Faqs.” CAHELP, www.cahelp.org/educators/edresources/esy-faqs. Accessed 18 Jan. 2025.
“Individuals with Disabilities Education Act (IDEA).” U.S. Department of Education, www.ed.gov/laws-and-policy/individuals-disabilities/idea. Accessed 21 Jan. 2025.
Kaczmarek, Sarah. “The Education for All Handicapped Children Act of 1975.” U.S. GAO, www.gao.gov/products/113316. Accessed 19 Jan. 2025.
Kraft, Rose. “Extended School Year Services (ESY) what the Courts Have Said.” EXTENDED SCHOOL YEAR SERVICES (ESY) WHAT THE COURTS HAVE SAID, nfb.org/images/nfb/publications/fr/fr19/issue1/f190119.htm. Accessed 14 Jan. 2025.
Stotland, Janet F., and Ellen Mancuso. “U.S. Court of Appeals Decision Regarding Armstrong v. Kline; the 180 Day Rule.” Exceptional Children, 31 Dec. 1980, eric.ed.gov/?id=EJ240506. “Extended School Year Faqs.” CAHELP, www.cahelp.org/educators/edresources/esy-faqs. Accessed 14 Jan. 2025.
Treppa, Michael S. “The Education for All Handicapped Children Act.” The Education for All Handicapped Children Act: Trends and Problems with the “Related Services” Provision, digitalcommons.law.ggu.edu/cgi/viewcontent.cgi?article=1433&context=ggulrev. Accessed 21 Jan. 2025.
