special education: discipline, lre and...

Special Education:

Discipline, LRE and

Attendance AIMEE R. ZUNDEL, ESQ.

ANNEMARIE K. HARR, ESQ.

© WBK LEGAL 2018 THIS PRESENTATION IS INFORMATIONAL ONLY AND DOES NOT CONSTITUTE LEGAL ADVICE.

1

Discipline of

Students with

Disabilities

“HERE’S THE SITUATION….

WHERE DO WE GO FROM

HERE?”

© WBK LEGAL 2018 THIS PRESENTATION IS INFORMATIONAL ONLY AND DOES NOT CONSTITUTE LEGAL

ADVICE.

2

Discipline of Students with Disabilities

Discipline of Eligible Students Must:

Be consistent with their IEP or Section 504 Plan

Be consistent with their PBSP, if applicable

NOT punish them for behavior caused by or substantially related to their disabilities

Be consistent with the Code of Student Conduct when behavior is NOT a manifestation of their disabilities


ADVICE.

3

IDEA and State Regulations

The IDEA allows school personnel to suspend a student with a disability for

a violation of the school’s code of student conduct in the same manner as

a student without a disability for up to 10 consecutive school days.

However, State Regulations prohibit punishing a student in any way for

behavior that is a manifestation of the student’s disability. 22 Pa. Code

14.33(e)(2).


ADVICE.

4

“Thought to Be”

Students who have not yet been determined to be eligible under the IDEA

may assert any available IDEA protections (e.g., due process,

manifestation determination reviews) where the district had knowledge or

should have known that the child had a disability before the occurrence

of the behavior that precipitated the disciplinary action. The concept of

protecting “thought to be” students is sometimes referred to as “once

suspected, then protected.”


5

“Thought to Be”

The District should have known if:

The parent has expressed concern in writing to the District supervisory

personnel or administration, or the child’s teachers that the child is in need

of special education and related services;

The parent has requested an evaluation of the child; or

The child’s teacher or any other district personnel has expressed specific

concerns about a pattern of behavior demonstrated by the child directly

to the director of special education, to other district supervisory personnel

or to the parents.


ADVICE.

6

“Thought to Be” – Ruled Out Where…

A parent has not allowed an evaluation or has refused services; or

The child has been evaluated and determined not to be eligible

(assuming the evaluation is sufficient). If the parents challenge the

evaluation, they may request an independent evaluation at the district’s

expense.


ADVICE.

7

When to do a Manifestation Determination

Review (MDR)?

1. >10 consecutive school days

2. When days 11-15 constitute a pattern of exclusion:

Series of removals constitute pattern

a) > 10 school days in school year (PA) AND

b) Behavior substantially similar to previous incidents AND

c) Such factors as length of each removal, total amount of time removed, proximity of

removals to one another

3. > 15 cumulative school days

4. An exclusion for even one school day for a student with intellectual disability

8


ADVICE.

Who Conducts MDR?

LEA Parent

“Relevant” members of IEP

team (determined by parent and LEA)

9


How to Conduct MDR?

• Review all relevant information: IEP, evaluations/reevaluations, disciplinary records, teacher

observations, relevant information provided by parents such as outside evaluations

• Two key determining factors regarding conduct in question:

If caused by, or had direct and substantial relationship to, child’s disability OR

If direct result of LEA’s failure to implement IEP or 504 Plan

• Examination of both school’s and child’s conduct

10


ADVICE.

Was the behavior caused by, or directly related to, the student’s disability?

OR

Was the behavior a direct result of the LEA’s failure to implement the IEP?

If YES to either of the above questions,

behavior IS a Manifestation of Disability

Conduct FBA

Implement behavioral intervention plan (PBSP)/Review PBSP and modify it as necessary to address the behavior

Return student to previous placement, unless

Special circumstances

Parents and LEA agree to change of placement after RR

IEP team makes decisions about FBA, PBSP, placement

If the answer to both questions is NO,

behavior IS NOT a Manifestation of

Disability:

Impose same consequences as applicable to student without disability

Continue to provide appropriate services

IEP team determines:

Services

Setting

Need for FBA/PBSP


ADVICE.

11

Special Circumstances: Drugs, Weapons,

Serious Bodily Injury

• Unilateral decision of LEA for removal regardless of whether manifestation or not

• For up to 45 school days

• Manifestation determination must be conducted

If manifestation, FBA and BIP required and removal limited to 45 school days

If not manifestation, same consequences as student without disability

Although drugs and weapons are straightforwardly defined in the law, serious bodily injury is

defined by its interpretation is heavily guided by case law.

12


Drugs, Weapons and SBI: Definitions

WEAPON

A weapon, device, instrument, material or substance, animate or inanimate, that is used for, or is readily capable of, causing death or serious bodily injury, except such term does not include a pocket knife with a blade of less than 2 ½ inches in length.

DRUGS

A controlled substance, which is defined as a drug or other substance identified under the Controlled Substances Act, and does not include a substance that is legally possessed or used under the supervision of a licensed health-care professional, or that is legally possessed or used under any other authority under that Act or under any other provision of Federal Law.

SERIOUS BODILY INJURY

A bodily injury that involves one or more of the following:

A substantial risk of death.

Extreme physical pain.

Protracted and obvious disfigurement.

Protracted loss or impairment of the function of a bodily member, organ, or mental faculty.


13

Case Study: Serious Bodily Injury (SBI)

and Likelihood of Causing SBI

S.S. and Pittsburgh Public School District, ODR Case No. 18270-16-17AS (2016)

Elementary aged student with an IEP, Positive Behavior Support Plan and Crisis Plan exhibited physical aggression (hitting, kicking, biting) towards staff on almost a daily basis. About a month into the school year after a series of aggressive behaviors, student attacked the school principal. The student jumped on the principal’s back and struck her multiple times in her head and neck area. Principal sought medical attention after a few hours, experienced numbness in the arms, had to attend physical therapy, was off work for two days, and was prescribed muscle relaxers and pain medication. The district referred the student to a 45-day unilateral placement based on the fact that she committed serious bodily injury.

The Hearing Officer found that this injury did not meet the definition of “serious bodily injury” outlined in the IDEA regulations and U.S. Code; however, the HO did order removal for a period of 45 days because the Student’s presence in the elementary school presented a substantial likelihood of injury to the Student and others.


14

IDEA Provision Authorizing Hearing

Officer Removal for 45 Days

Where a student’s continued presence in the normal school environment

presents a substantial likelihood of injury to the student or others, then a

hearing officer is authorized to order a change in placement to an Interim

Alternative Educational Setting (IAES) for 45 days. See 20 U.S.C. §

1415(k)(3)(B)(ii)(II).


15

Case Study: Manifestation

Determinations under Section 504

Doe ex rel. Doe v. Osseo Area Sch. Dist. ISD No. 279, 117 LRP 46232 (D. Minn. 10/31/17)

High schooler with ADHD, PTSD and depression was disciplined for writing racist and hostile graffiti in a school restroom. In the scope of applying proposed discipline, the school conducted a manifestation determination review. MDR team considered whether the student’s misconduct was caused by or had a direct and substantial relationship to his disability. They determined it did not.

Parents argued that the team should have been asking whether the behavior had “any connection” to the student’s diagnoses.

The Court concluded that the same MDR process must be followed under both IDEA and Section 504, and rejected the parents’ argument for a lesser MDR standard under Section 504.


16

Red Flag Practices

Sending student home “off the record”

Sending a student with a disability home for the day (regardless of time of day

and parent agreement) without documenting the day or the portion of the day

as a suspension.

Return with a parent

Requiring a student to return with a parent before being readmitted to school

Bus suspensions

When a student is suspended from the bus, alternative transportation can be

provided, but if not it may count as a day of suspension and compensatory

education may be ordered upon review

© WBK LEGAL 2018 THIS PRESENTATION IS INFORMATIONAL ONLY AND DOES NOT CONSTITUTE

LEGAL ADVICE.

17

What Would You Do?

A 7th grade student with an

intellectual disability was

selling drugs in the cafeteria. What would you do?


ADVICE.

18

What Would You Do?

A 9th grade student with Autism

asked multiple female students

graphic questions about their sexual

experience. One female student

reported that she felt violated, and

upon investigation additional

students were identified. What would

you do?


LEGAL ADVICE.

19

Least Restrictive

Environment WHEN IS AN OUTSIDE

PLACEMENT APPROPRIATE


ADVICE.

20

Understanding LRE


LEGAL ADVICE.

21

What Does the Law Say?

Under 34 CFR 300.114 (a)(2), each public agency must ensure that:

(i) To the maximum extent appropriate, children with disabilities, including

children in public or private institutions or other care facilities, are

educated with children who are nondisabled; and

(ii) Special classes, separate schooling, or other removal of children with

disabilities from the regular educational environment occurs only if the

nature or severity of the disability is such that education in regular classes

with the use of supplementary aids and services cannot be achieved

satisfactorily.


ADVICE.

22

https://www.specialedconnection.com/LrpSecStoryTool/servlet/GetReg?cite=34+CFR+300.114

What Does the Law Say?

The IDEA requires that the placement:

Be based on the child's IEP.

Allow for the implementation of the IEP.

Be as close as possible to the child's home.

Is, to the extent appropriate, in the age-appropriate general education setting.

Is in the LRE.

Is, unless the IEP requires another arrangement, in the school that he or she

would attend if not disabled.

34 CFR 300.116


ADVICE.

23


Let’s Break it Down!

A more restrictive setting will only be appropriate when the School

District can show that: the nature or severity of the disability is such

that education in regular classes with the use of supplementary

aids and services cannot be achieved satisfactorily.

So we must be able to show what supplementary aids and

services have been attempted and have been successful/unsuccessful.


ADVICE.

24

Let’s Break it Down!

The IDEA requires that the placement:

Be as close as possible to the child's home.

Is, unless the IEP requires another arrangement, in the school that he or she

would attend if not disabled.

Does this mean that it must be in the neighborhood school?

Not necessarily – if the District can show that a student could not be placed in

his neighborhood school because it does not offer the appropriate aides and

services, another program may be sufficient. H.D. v. Central Bucks Sch. Dist., 59

IDELR 275 (E.D. Pa. 2012)


25

https://www.specialedconnection.com/LrpSecStoryTool/servlet/GetCase?cite=59+IDELR+275

Data, Data, Data

In order to show that a more restrictive setting is appropriate we must have

data to support what has been attempted.

Did you add a Paraprofessional into the classroom to aide in the management

of the student at issue? Document it!

Did you try more intensive behavior interventions? Call an IEP team and add it

to the plan?

Is the student using the resource room for a greater amount of time than the IEP

originally planned for? Update the IEP!


ADVICE.

26

Have We Traveled the Continuum?

34 C.F.R. §300.115

Continuum of alternative placements. (a) Each public agency must

ensure that a continuum of alternative placements is available to meet

the needs of children with disabilities for special education and related

services.(b) The continuum required in paragraph (a) of this section must—

(1) Include the alternative placements listed in the definition of special

education under §300.309 (instruction in regular classes, special classes,

special schools, home instruction, and instruction in hospitals and

institutions); and(2) Make provision for supplementary services (such as

resource room or itinerant instruction) to be provided in conjunction with

regular class placement.


ADVICE.

27

Defining the Terms

The IDEA and implementing regulations do not define the terms "resource

room" or "itinerant instruction." They merely mention these terms as

examples of supplementary services that can be provided in conjunction

with regular education. Letter to Copenhaver, 25 IDELR 1213 (OSEP 1997).

The term "itinerant" instruction generally refers to a variety of services,

which can be offered at various locations throughout the school building.

A "resource room" is a specially equipped and staffed classroom in a

regular school in which students with disabilities spend part of their day

receiving individualized instruction or skills remediation with the balance of

the day spent in a regular classroom. See New Haven Bd. of Educ., 110 LRP

4313 (SEA CT 10/30/09).


28


https://www.specialedconnection.com/LrpSecStoryTool/servlet/GetCase?cite=110+LRP+4313

In-District “Special Schools”

Establishing schools exclusively for students with a particular disability

classification does not in itself run afoul of the IDEA. However, IEP teams

that have such a placement option available to them must ensure that it is

only one of the choices they consider and that their decision is ultimately

based on the child's individual needs with an eye toward placing the

student in the LRE. Letter to Autin, 58 IDELR 51 (OSERS 2011).


ADVICE.

29


Have We Really Tried it All?

Klein Indep. School Dist. 63 IDELR 240, (2013)

Facts: At his initial point of identification, a student with autism was placed in a

general education environment for science and social studies, with a modified

curriculum and in a special education resource room for math an English. After

conducting additional assessments and an IEE, the District recommended a

special education program for all academic subjects and social skills. Parents

rejected this offer and instead consented to the special education program for

most academics on a trial basis, and the resource class for math and English. At

the end of the school year, the District again informed the parents that the

student would be in the previously proposed placement for all core academic

subjects and social skills. Parents declined and filed for due process alleging a

failure to educate in the LRE.


30

Klein Indep. Sch. Dist. cont.

Decision: The School District was able to show the hearing officer that in order for the student to remain in the program that the parents were seeking, the District had to create a “classroom within a classroom” to meet his needs; has to modify the already modified curriculum in the resource room; and had to attend to him one on one at all times to keep him on task.

The hearing officer acknowledged that the student “depended so much on intense one-on-one instruction, reinstruction, and reinforcement that the

student visibly lacked the necessary skills to make progress in general education, even with accommodations and modifications. The hearing officer noted that the student’s progress in the general education classroom was minor and that the student was less stimulated, participated more, and was less frustrated in the special education program.


31

What Must You Prove?

H.L. v. Downingtown Area Sch. Dist. 65 IDELR 223 (3d Cir. 2015).

Facts: A Pennsylvania School District determined that a student with

multiple SLDs could not be educated in the regular education setting for

reading and writing instruction. The District could offer no evidence that

the student required pull-out services in language arts for 90 minutes a

day. In the NOREP that was issues, the District only considered full-time

general education placement and rejected that option as being

inadequate.


ADVICE.

32

H.L. v. Downingtown Cont.

Decision: The court found that there was no evidence of how the District

actually approached the LRE issue, and only limited evidence of what

options may have been available. The District argued that the lack of

appropriate documentation was a procedural flaw that did not amount to

a substantive denial of FAPE, but the court disagreed, finding that “the

issue was not whether the IEP and placement notice adequately recorded

the placement discussion, but whether that discussion occurred at all.”

Because the District could not identify the factors that it considered when

it determined that pull-out instruction was required, the court found in

favor of the parent.


33

When You Have Tried it All

If a District can demonstrate that a student requires a level of services

greater than what can be offered in the District, an approved private

school may be appropriate.


ADVICE.

34

Who has the Responsibility?

Each LEA must ensure that a child with a disability who is placed in or referred to a private school or facility by a public agency:

a) Is provided special education and related services --

1) In conformance with an IEP that meets the requirements of 34 CFR 300.320through 34 CFR 300.325 ; and

2) At no cost to the parents;

b) Is provided an education that meets the standards that apply to education provided by the SEA and LEAs including the requirements of this part, except for 34 CFR 300.156 (c); and

c) Has all of the rights of a child with a disability who is served by a public agency.

34 CFR 300.146.


35





Who has the Responsibility?

In implementing 34 CFR 300.146 , the SEA must:

a) Monitor compliance through procedures such as written reports, on-site

visits, and parent questionnaires;

b) Disseminate copies of applicable standards to each private school and

facility to which a public agency has referred or placed a child with a

disability; and

c) Provide an opportunity for those private schools and facilities to

participate in the development and revision of state standards that apply

to them.

34 CFR 300.147.


36



Reminders!

If a student is placed in a private facility, the LEA still has the responsibility

to provide FAPE!

And the liability if FAPE is not provided!

A member from the LEA must be at the annual IEP meetings, even if

facilitated through the private school!

The LEA should be reviewing student’s placed at APS’ in order to

determine if it continues to be the Least Restrictive Environment for the

student!


ADVICE.

37

Attendance,

Truancy, School

Phobia

OH MY!


38

Attendance – The Basics

Absences shall be treated as unlawful until the district receives a written

excuse explaining the absence, to be submitted within three (3) days of

the absence.

A maximum of ten (10) days of cumulative lawful absences verified by

parental notification shall be permitted during a school year. All absences

beyond ten (10) cumulative days shall require an excuse from a licensed

practitioner of the healing arts.


39

Attendance – Lawful Absences

Illness, including if a student is dismissed by designated district staff during

school hours for health-related reasons.

Obtaining professional health care or therapy service rendered by a

licensed practitioner of the healing arts in any state, commonwealth or

territory.

Quarantine.

Family emergency.

Recovery from accident.

Required court attendance.

© WBK LEGAL 2018 THIS PRESENTATION IS INFORMATIONAL

ONLY AND DOES NOT CONSTITUTE LEGAL ADVICE.

40

Attendance – Lawful Absences

Death in family.

Participation in a project sponsored by a statewide or countywide 4-H, FFA

or combined 4-H and FFA group, upon prior written request.

Observance of a religious holiday observed by bona fide religious group,

upon parental request.

College or postsecondary institution visit, with prior approval.

Other urgent reasons. Urgent reasons shall be strictly construed and do not

permit irregular attendance.


ADVICE.

41

Truancy – Act 138

New Definitions:

• Truant – having incurred three (3) or more school days of unexcused absences during the current school year by a child subject to compulsory school attendance laws

• Habitually Truant – having six (6) or more school days of unexcused absences during the current school year by a child subject to compulsory school attendance under this article


LEGAL ADVICE.

42

Truancy – Act 138

New Requirements – School Attendance Improvement Conference

• After a student has been truant (3 unexcused absences) the school must offer a School Attendance Improvement Conference (SAIC).

• Notice of conference must include:

• A description of consequences if the student becomes habitually truant (which includes 6 days of unexcused absences)

• Must be in mode or language preferred by parent (or person in parental relation)

• If those in attendance are an IEP Team, consider issuing an IEP Invitation along with the SAIC invitation


43

SAIC– Who Should I Invite?

• Parent/Guardian/“Person in parental relation, other individuals identified by the person in parental relation as a resource”

• Child

• Appropriate School Personnel

• IEP Team Members/504 Team Members!

• Recommended Service Providers

The school must hold the conference and create documentation even if parent/student do not attend!


ADVICE.

44

SAIC – What Are We Going to Talk

About?

• Discuss reasons for unexcused absences

• Create a School Attendance Improvement Plan

• No legal action may take place until scheduled date for School

Attendance Improvement Conference has passed.

• School may not expel or impose out of school suspension, disciplinary

reassignment, or a transfer for truant behavior.

• Verification of the conference is required before a referral is made to a

children and youth agency


45

What Happens Next?

School Attendance Improvement Plan:

Outcome of the SAIC must be documented in a written

School Attendance Improvement Plan.

Provide a copy to the parent/guardian, student and

appropriate school staff.

The school may not take further legal action to address

unexcused absences until after the date of the scheduled

School Attendance Improvement Conference has passed.


ADVICE.

46

What If the Student Still Doesn’t Attend?

Students who are under 15:

Refer the child to school-based or community-based attendance improvement program

Referral to county children and youth agency for services or possible disposition as a “dependent child”

File a citation against person in parental relation


ADVICE.

47

What If the Student Still Doesn’t Attend?

Students who are 15 or Older:

Refer the child to a school-based or community based attendance improvement program or service

Refer child to county and youth agency as a dependent child if

the child continues to incur additional unexcused absences or

refuses to participate in a school based program

File a citation against the child or person in parental relation


ADVICE.

48

Truancy Proceedings

Burden of proof is on the District to prove

beyond a reasonable doubt that the child was

habitually truant without justification

It is a defense if Parent can show that they took

every reasonable step to ensure attendance


ADVICE.

49

Truancy Penalties

• Child 15 years or older

• Fine not to exceed $300 combined with court costs

• Perform community service

• Complete course/program designed to improve school attendance

• Parent

• First offense – fine not to exceed $300 combined with court costs

• Second offense – fine may exceed $300 based on ability to pay, but not greater than $500

• Third offense – fine may exceed $500 based on ability to pay, but not greater than $750


LEGAL ADVICE.

50

But Wait, There’s More!

Red Flag Reminder!

Attendance issues are often a red flag for outlying issues

that may later lead to liability

Title IX – Bullying and Harassment

Continuing Child Find Obligation

Consider a Reevaluation


ADVICE.

51

School Phobia – the Double Edged Sword

If the student is a student with a disability (IEP or 504) be

sure to address school phobia in the IEP/504

Will the District pursue truancy?

How is the school addressing the school avoidance?

SDI/Accommodations to address?

Has homebound been offered?


52

School Phobia

If the student is not yet identified – if

absences and tardiness becomes

unmanageable and a SAIC/SAIP have

been unsuccessful – it may be time to

initiate an evaluation!


ADVICE.

53

Truancy and IDEA Eligibility

Lack of attendance, on its own, does not qualify a student for special education. Board of Educ. of Syracuse City Sch. Dist., 37 IDELR 232 (SEA NY 2002). However, it may help establish that the student has an impairment that results in a need for special education and related services, an element required to establish eligibility under the IDEA. 34 CFR 300.8 (a)(1).

When it comes to < truancy >, emotional disturbance is the eligibility category that is typically at issue. Under the IDEA implementing regulation 34 CFR 300.8 (c)(4)(i), "emotional disturbance" means a condition exhibiting one or more of the following characteristics "over a long period of time and to a marked degree that adversely affects a child's educational performance":

(A) An inability to learn that cannot be explained by intellectual, sensory, or health factors.

(B) An inability to build or maintain satisfactory interpersonal relationships with peers and teachers.

(C) Inappropriate types of behavior or feelings under normal circumstances.

(D) A general pervasive mood of unhappiness or depression.

(E) A tendency to develop physical symptoms or fears associated with personal or school problems.


ADVICE.

54



https://www.specialedconnection.com/LrpSecStoryTool/index.jsp?contentId=10005&chunkid=371504&query=((TRUANCY))&topic=Main&chunknum=1&offset=0&listnum=0#ctx8

https://www.specialedconnection.com/LrpSecStoryTool/index.jsp?contentId=10005&chunkid=371504&query=((TRUANCY))&topic=Main&chunknum=1&offset=0&listnum=0#ctx10


Caselaw

Urban Pathways Charter School ODR File No.

2617-11-12AS (2012)

Facts: A student was initially identified as a

student with a disability under the disability

category of SLD. His IEP indicated that he did

not have behaviors that impeded his learning or

the learning of others.


ADVICE.

55

Caselaw Cont.

Facts: The student was failing to make progress, and receiving disciplinary

infractions, and had missed 47 days total. The parent claimed that the

student “just did not want to go to school.” The School dealt with the issue

by following typical protocol involving calling home, and sending letters to

the parent, but did not hold an IEP meeting to address the absences.

Decision: Parents sued after student failed to make progress on reading

goals; school claimed that the lack of progress was due to the

attendance issues but the hearing officer found that the District had the

responsibility to determine the cause of truancy and address it with

behavioral interventions.


ADVICE.

56

What Can the District Do?

Downingtown Area School District ODR File No. 13375-1213KE

Facts: During student’s 6th and 7th grade year, parents began un-enrolling and re-enrolling student between the students brick and mortar school and the district’s cyber program. According to the parents, this was due to the student’s school based anxiety. School District, in the 8th grade initiated a re-evaluation of the student, citing the student’s school avoidance as one reason for the re-evaluation. Following the re-evaluation, the school district provided a number of modifications to the student including the following relating to student’s attendance issues: attendance monitoring and protocol for work completion, increased wait time for responses, requiring answers other than “I don’t know.”

The student’s attendance did not improve, and the District sought an additional re-evaluation including an FBA with a home visit. Parents declined consent for the home visit.


57

Downingtown Cont.

Facts: The re-evaluation included reports from the parents claiming that

the student had anxiety, although District did not see this at school. The

parents also indicated that the student had unusual sleep habits and was

often tired during the day. Based on the information the District collected,

it recommended the student for an Intensive Outpatient program

specifically designed for students who were experiencing difficulties

adjusting in school. The IEP team made additional revisions to the IEP to

allow for the student to turn in work late if it was not turned in due to

absences, as well as offering rewards for attendance. The District did not

limit the student’s ability to participate in extra-curriculars on days she

missed school, despite school policy to the contrary.


ADVICE.

58

Downingtown Cont.

Facts: The School District eventually filed for truancy against the student when the student still refused to attend.

Decision: The parents eventually filed for due process claiming that the District failed to provide FAPE because the student was continuing to have school phobia and school avoidance issues. The parents also claimed that the District should have initiated another FBA rather than to file for truancy. The hearing officer found that the District offered a variety of interventions to help to student attend school, and that the parents did not follow through with outside interventions. The Hearing Officer found that it was only after the District’s efforts failed in attempting to get the student back to school did it move the problem up to the higher authority of the court, and that this action was appropriate.


59

Questions???

Aimee R. Zundel, Esquire

[email protected]

Annemarie K. Harr, Esquire

[email protected]

Weiss Burkardt Kramer, LLC

445 Fort Pitt Blvd., Suite 503

Pittsburgh, PA 15219

Phone: (412) 391-9890


60

mailto:[email protected]

mailto:[email protected]

special education: discipline, lre and...

Documents