Special education has undergone continued transformation since societies began to provide an increasing number of specialized, segregated facilities for children with like needs during the 20th century. Since then, there has been a worldwide movement against a segregated approach and toward greater inclusion of students with disabilities into regular schools. The provision of a dual special education and regular school system, nevertheless, remains in existence, even though there has been a strong emphasis on a more inclusive approach since the latter half of the 20th century. As regular schools become more inclusive and teachers more capable of providing appropriate modifications for most students with learning needs, simultaneously there has been an increase in the number of students whose needs are so severe that schools have not been able to accommodate them. While these children and youth have special needs, they are invariably not related to an identified disability but fall more into a category of diversity. In particular, students who are excluded from schools due to severe infringements, those who are disenfranchised from school and refuse to attend, and those with severe emotional, behavioral, or mental health issues are not being serviced by the existing dual system. For these students neither existing special schools that cater to students with disabilities nor regular inclusive schools provide an appropriate education. The provision of a complementary and alternatively focused education to cater to the specific needs of these marginalized students seems to be developing to ensure sustainability of education and to prepare these new groups of students for inclusion into society upon leaving school. This tripartite approach highlights a new era in the movement toward a sustainable, inclusive education system that caters to the needs of all students and specifically those with the most challenging and diverse requirements.
Patterson v. McLean: A Confirmation of the New Right at the U.S. Supreme Court
