18 J.L. & Educ. 215 (1989)
Into the Turbulent Mainstream - A Legal Perspective on the Weight to Be given to the Least Restrictive Environment in Placement Decisions for Deaf Children

handle is hein.journals/jle18 and id is 225 raw text is: Into the Turbulent Mainstream-
A Legal Perspective on the Weight to be
Given to the Least Restrictive Environment
in Placement Decisions For Deaf Children
Championship prowess will sooner be attained if she concentrates on intensive
training and learning to swim before she plunges unprepared into the turbulent
mainstream. When her strokes are stronger she will be able to make better head-
way in the water.'
One of the goals of the Education for All Handicapped Children Act
(EAHCA or Act) is to educate handicapped children with nonhandi-
capped children to the maximum extent appropriate.2 This concept of
educating children in the least restrictive environment (LRE) has provoked
more controversy and confusion than any other issue in special education.
Nowhere has this controversy been more acute than in the field of deaf
education. Deafness creates obstacles to acquisition of language and com-
munication. To help overcome these obstacles to learning, deaf children
require an intensive language development environment staffed by highly
trained professionals in deafness and often require special programs.
There are concerns, however, that placements guided by the mainstream-
ing principle may not be appropriate for many of these children. As the
Commission on Education of the Deaf found in its Report to the President
and the Congress of the United States:
Parents, deaf consumers, and professional personnel of all persuasions have,
with almost total unanimity, cited LRE as the issue that most thwarts their at-
tempts to provide an appropriate education for children who are deaf.3
* Legal Director of the National Center for Law and the Deaf, Gallaudet University, since 1975.
Member of Virginia and District of Columbia Bar; B.A., Northwestern University, 1965; J.D.,
George Washington National Law Center, 1968. Mr. DuBow is co-author of the book, LEGAL RIGHTs
OF HEARING-IMPAIRED PEOPLE. The author thanks Sarah Geer for her editorial assistance.
1. Grkman v. Scanlon, 528 F. Supp. 1032, 1037 (W.D. Pa. 1981).
2. 20 U.S.C.  1412(5) (1982).

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