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39 Hofstra L. Rev. 757 (2010-2011)
Grooming Dogs for the Educational Setting: The IDEIA behind Service Dogs in the Public Schools

handle is hein.journals/hoflr39 and id is 763 raw text is: NOTE GROOMING DOGS FOR THE EDUCATIONAL SETTING: THE IDEIA BEHIND SERVICE DOGS IN THE PUBLIC SCHOOLS I. INTRODUCTION Service dogs traditionally have been used to guide people with visual impairments, acting as their eyes and helping them to independently perform daily functions.' However, service dogs are also valuable for people with other types of disabilities, including hearing impairments,2 autism spectrum disorder,3 seizure disorders,4 and physical handicaps.5 For students with disabilities, service dogs can help them become more independent,6 improve their focus,7 help them socialize,8 and ensure their safety.9 Despite the positive impact service 1. See Rebecca J. Huss, Why Context Matters: Defining Service Animals Under Federal Law, 37 PEPP. L. REv. 1163, 1167 (2010). 2. See Cave v. E. Meadow Union Free Sch. Dist., 480 F. Supp. 2d 610, 619 (E.D.N.Y. 2007) (noting the testimony of the plaintiff describing how a service dog may alert a child of sounds that he otherwise cannot hear). 3. Danny Schoenbaechler, Autism, Schools, and Service Animals: What Must and Should Be Done, 39 J.L. & EDUC. 455, 459-60 (2010) (describing how service dogs provide education and safety benefits for children with autism). 4. Michael Inbar, School Bars 12-Year-Old Epileptic Boy's Service Dog, TODAY (Jan. 4, 2011, 10:11:22 AM), http://today.msnbc.msn.com/id/40907000/ns/today-todayhealth/ (discussing how a student with a rare and severe form of epilepsy uses a service dog to identify seizures and keep him safe while seizing). 5. Jennie Dapice, Service Dogs and People with Limb Loss, INMOTION, May-June 2007, at 26, available at http://www.amputee-coalition.org/inmotion/mayjun_07/service-dogs.html (noting that service dogs are helpful for individuals with limb loss). 6. See Branson v. West, No. 97 C 3538, 1999 WL 1186420, at *4 (N.D. Ill. Dec. 10, 1999) (describing how a service animal helps a woman in a wheelchair be more independent by retrieving items and bracing for her when she transfers from her wheelchair to her bed). 7. See Kalbfleisch v. Columbia Cmty. Unit Sch. Dist. Unit No. 4, 920 N.E.2d 651, 656 (I11. App. Ct. 2009) (describing how a service dog stopped a child with autism from stimming by batting him with his nose, allowing the child to maintain focus). 8. See Bonnie Mader et al., Social Acknowledgements for Children with Disabilities: Effects of Service Dogs, 60 CHILD DEV. 1529, 1531 (1989) (describing the results of a study indicating that children who were observed with service dogs received more social interaction by passersby than those children without a service dog). 9. See K.D. v. Villa Grove Cmty. Unit Sch. Dist. No. 302 Bd. of Educ., 936 N.E.2d 690, 694 (I11. App. Ct. 2010) (describing testimony about a dog who prevented an autistic child from running away); Kalbfleisch, 920 N.E.2d at 656 (discussing how a dog physically took a child down when he

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