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In 1966, the President's Panel on Mental Retardation published a booklet entitled The Six Hour Retarded Child. This booklet noted that many students were labeled "mentally retarded" based on their school work rather than their level of functioning in their family and community.

The use of labels emphasized not only that education must improve for students with disabilities, but also that applying a label to one part of an individual's life results in stigmatizing a person's entire life.

Not only was much of the existing schooling inadequate or misplaced, but significant numbers of children with disabilities were not being educated at all. Thousands of children were simply turned away by schools who said they were unable to educate them and were not required by law to do so.

The Six Hour Retarsed Child

In 1973, Marian Wright Edelman, founder of a new organization called the Children's Defense Fund, conducted a survey to determine why 750,000 children appeared in the U.S. Census as not attending school. Edelman suspected that the number represented African-American children kept out of school in segregated settings. In fact, they were children with disabilities. This data assisted the Pennsylvania Association for Retarded Children in its lawsuit regarding the exclusion of children with disabilities from school as a violation of the equal protection clause of the U.S. Constitution. The Federal District Court ruled in favor of the children, which led to the enactment of a federal law mandating their education.