How This Court Case Redefined Inclusion
What D.R. vs Redondo Beach Unified School District means for your child's rights
The way we determine Least Restrictive Environment (LRE) for our students with disabilities is fundamentally changing, and it's about time.
As a special education advocate who's worked with hundreds of families navigating IEP decisions, I've seen firsthand how the interpretation of LRE can make or break a student's educational experience. In the past few years since the 2022 D.R. vs Redondo Beach Unified School District case, a new framework for these crucial decisions has evolved—one that finally puts the focus where it belongs: on comprehensive student success rather than just physical placement.
Today, we're diving deep into:
- How this landmark case reshapes LRE discussions 
- What it means for your child's educational rights 
- Practical steps for collaborative decision-making 
If you're struggling to advocate for appropriate inclusion and support for your child, or feeling frustrated by placement discussions that seem to prioritize administrative convenience over student needs, this breakdown is essential reading.
Weekly Resource List:
- Effective Communication Strategies- Templates and scripts for working with school teams 
- Key Court Decisions Shaping LRE Requirements - A modern analysis of court cases involving LRE through the lens of new and evolving technology 
- Collaborative IEP Meeting Checklist - Transform meetings from confrontational to cooperative 
- IEP Rights Checklist- A guide to help you evaluate whether your child's program meets legal standards 
- Monthly Update Email Template - Keep everyone aligned and engaged 
The Game-Changing Court Decision
The 9th Circuit's ruling in DR v. Redondo Beach (2022) made several critical points that every parent should understand:
- LRE decisions must consider the full range of supplementary aids and services that could support inclusion 
- Schools must make good-faith efforts to implement these supports before moving to more restrictive environments 
- The burden is on the school district to prove that a more restrictive placement is necessary 
Current Challenges in Implementation
Here's where things get complicated. As COVID-19 relief funds expire, districts nationwide face staffing and resource constraints that directly impact their ability to provide comprehensive support services. However, the court's ruling makes it clear: financial constraints alone cannot justify more restrictive placements.
A Collaborative Framework for Success
To navigate these challenges effectively, we need a new approach to LRE discussions. Here's what that looks like:
1. Comprehensive Student Assessment
- Academic performance 
- Social-emotional needs 
- Communication abilities 
- Sensory requirements 
- Executive functioning skills 
2. Support Service Mapping
- Identify necessary accommodations 
- Detail required modifications 
- List supplementary aids and services 
- Specify staff training needs 
- Outline environmental adaptations 
3. Implementation Planning
- Create clear timelines 
- Establish progress monitoring systems 
- Define communication protocols 
- Build in regular review periods 
- Develop contingency plans 
That's it.
Here's what we discussed today:
- The D.R. v. Redondo Beach ruling strengthens students' rights to meaningful inclusion 
- Financial constraints cannot be the primary factor in placement decisions 
- Success requires systematic planning and collaboration 
What matters now is putting this knowledge into action. Start by reviewing your child's current IEP through this new lens. Are all possible supports being considered? Is there a clear plan for implementation and monitoring?
To help you get started, I've created a LRE Support Analysis Worksheet that walks you through evaluating your child's current placement and identifying potential areas for enhanced support.
Remember: Successful inclusion isn't just about being in the general education classroom - it's about having the right supports to thrive there. Let's work together to make that happen for every student.
All the best,
Megan
Let’s connect on socials: Twitter/X | Instagram | Facebook | TikTok | Bluesky
Looking for a particular resource? Shoot me an email and let me know and you may just see that resource included in next week’s newsletter.
PS... If you're enjoying SPED Code, please consider referring this edition to a friend.



