As a result of a policy of "full inclusion," 9-year-old Rachel Holland, who is mentally retarded with an IQ of 44 and a mental age of 4, attends regular classes in California. Although she had been observed staring vacantly at a textbook placed upside-down in front of her, the U.S. Court of Appeals for the Ninth Circuit ruled that Rachel was a fully participating member of the class.

In New Jersey, Rafael, a mentally retarded 5-year-old who cannot speak intelligibly and who must be taken to the bathroom every 15 minutes, has created havoc with frequent outbursts, tantrums, and assaults on teachers, aides, and other students.

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