Forest Grove v. T.A . Rejoinder to Zirkel

Abstract

In this issue, Professor Perry Zirkel argues that the points presented in the Dixon, Eusebio, Turton, Wright, and Hale treatise of the Forest Grove School District v. T.A. Supreme Court case confuses “legal requirements with professional norms.” Although we appreciate Zirkel’s acknowledgment that our position reflects the professional norm—that comprehensive evaluation of psychological processes is critical for identifying children with learning and other disabilities—this position does not equate with “confusion” regarding the Individuals with Disabilities Education Improvement Act statutory or regulatory requirements, or legal precedents, presented in Dixon et al. On the contrary, Dixon et al. specifically address all three requirements in their article, suggesting Zirkel’s rebuttal is not supported. The resultant effects of Zirkel’s arguments on public opinion, professional conduct, and individual children served by the law will be elucidated in this rebuttal.