Sacramento City Unified School District, Board of Education v. Holland (1994)

By Andrew Dawson

Overview

In Sacramento City Unified School District, Board of Education v. Holland, the 

​​United States Court of Appeals for the Ninth Circuit ruled the appropriate educational placement for Rachel Holland was regular classroom full-time with some supplemental support under the Individuals with Disabilities Act (IDEA) (Studicata). 

Summary

Rachel Holland was a student in Sacramento City School District with severe developmental disabilities. From 1985 to 1989, she attended a variety of special education programs. Yet, her parents sought to place Rachel into a regular classroom for the 1989-90 school year. The School District rejected their request and instead proposed an Individualized Education Program (IEP) that would split Rachel’s time between special education and regular classes. This plan would have required moving Rachel six times in the school day. Her parents rejected this proposal and instead enrolled her into a regular classroom at a private school, where Rachel would remain until second grade. The Holland’s also appealed the District’s placement decision to a state hearing officer. They agreed with the Holland parents and stated “that Rachel best learned social and academic skills in a regular classroom and would not benefit from being in a special education class” (Justia Law). 

The School District appealed the state hearing officer’s determination to the United States District Court for the Eastern District of California. The District Court also affirmed the decision of the hearing officer stating “Rachel should be placed full-time in a regular classroom” (Justia Law). To support their case in District Court, Holland’s parents provided evidence of Rachel’s academic performance and aptitude tests. Two of Rachel’s teachers from private school also served as witnesses and testified that Rachel was “independent, self-confident, and eager to learn as most second-graders.” Additionally, the teachers testified that Rachel’s accommodations were not a burden to the classroom and her age difference (two years older than most students) did not present challenges either (Gray). 

The United States District Court for the Eastern District of California applied a four part test to determine an appropriate placement for Rachel: 

(1) the educational benefits available to Rachel in a regular classroom, supplemented with appropriate aids and services, as compared with the educational benefits of a special education classroom; (2) the non-academic benefits of interaction with children who were not disabled; (3) the effect of Rachel's presence on the teacher and other children in the classroom; and (4) the cost of mainstreaming Rachel in a regular classroom (Justia Law). 

The District Court found for each of these factors, the educational benefits to Rachel weighed significantly in favor of placing her in a regular classroom. The District Court said that all of Rachel’s IEP goals could be implemented in a regular classroom, although acknowledging that some curriculum modifications might be necessary and Rachel would need the assistance of a part-time aide (Justia Law).

The School District appealed the District Court’s decision to the United States Court of Appeals for the Ninth Circuit, which again reaffirmed the District Court’s ruling for Rachel to be placed in a regular classroom. The Ninth Circuit of Appeals stated that the District Court implemented the correct criteria for this decision: Educational Benefits, Non-academic Benefits, Effects on the Teacher and Other Children, and Costs. The Ninth Circuit of Appeals noted the Educational Benefits were clear and reaffirmed by the “credible testimony” by Rachel’s private school teachers. The Non-academic Benefits would also be to Rachel’s advantage, such as socially, with her self-confidence, and her excitement with school and learning. Further, the Ninth Circuit noted the effects on Rachel’s teachers and other children would be minimal, as noted by her teachers to the District Court. Finally, the Ninth Circuit found that the School District’s costs for Rachel’s education would be lower in a regular classroom than in a special education classroom, or through needing to reimburse the Holland’s for private school. Further, the Ninth Circuit found that the School District’s proposed cost estimates to the Court were “inflated and unconvincing” (Studicata).

On June 13, 1994, the US Supreme Court rejected without comment the appeal from the School District in Sacramento City Unified School District v. Holland (Walsh). 

Impact

One key impact was during the School District’s appeal to the Ninth Circuit, when the Clinton Administration filed a brief in favor of the goal of full inclusion for students with disabilities (Walsh). Another impact from this case provides another precedent that parents are able to challenge their child’s IEP, educational placement, and the educational services they receive from their local public school in federal court. 

Court Documents

Link to Full Sacramento City Unified School District, Board of Education v. Holland Ruling

Link to Individuals with Disabilities Education Improvement Act of 2004 (Updated Amendments to IDEA) (now known as IDEIA) 

Link to IDEA Parent Guide (IDEA: 2004)

Citations

Gray, Nicole. Board of Education, Sacramento City Unified School District v. Holland, Quimbee, www.quimbee.com/cases/board-of-education-sacramento-city-unified-school-district-v-holland. Accessed 14 Feb. 2025.

“Sacramento City School Dist. V. Rachel H.” Studicata, studicata.com/case-briefs/case/sacramento-city-school-dist-v-rachel-h/. Accessed 14 Feb. 2025. 

Sacramento City Unified School District, Board of Education, Plaintiff-Appellant, v. Rachel H., by and Through Her Guardian Ad Litem, Robertholland; William Honig, California State Superintendent Ofpublic Instruction; California State Department Ofeducation Hearing Office, Mcgeorge School of Law; and Marycote, Hearing Officer, Defendants-Appellees, 14 F.3d 1398 (9th Cir. 1994), Justia Law, law.justia.com/cases/federal/appellate-courts/F3/14/1398/613232/. Accessed 14 Feb. 2025. 

Walsh, Mark. Supreme Court Rejects Appeal of Rulings Favoring “Full Inclusion,” Education Week, 27 Sept. 2021, www.edweek.org/education/supreme-court-rejects-appeal-of-rulings-favoring-full-inclusion/1994/06.