Amostra

The coverage was limited to court decisions due to their precedential weight, or superseding effect, in relation to hearing and review officer decisions. The primary sources of the court decisions were the electronic databases of (a) Westlaw, which includes citations for the Federal Reporter (F.3d) and the Federal Supplement (F. Supp. 3d), and (b) LRP’s Special Ed Connection®, which yields citations to the Individuals With Disabilities Education Law Report (IDELR). However, the search extended to the court deci sions cited in secondary sources in the special education and legal literatures. The time period had no specified starting point, but, not surprisingly, the relevant rulings did not appear until the early 1990s in light of the aforementioned 1990 amendments of the IDEA. The end point of coverage was December 31, 2016. The Boolean search in the two databases used “transi tion” and “transition services” in combination with “indi vidual with disability education act” OR “special education,” including the expander wild cards for each database. The topical index of Special Ed Connection® and the case cita tions within the initially identified court opinions provided additional potentially relevant judicial rulings. The basic selection criterion was that the court decision included a ruling specific to transition services within the aforementioned legal framework. Further delineating the boundary, the exclusions were judicial rulings that addressed the following separable issues: (a) transition between Part C and Part B (e.g., Blount County Board of Education v. Bowens, 2014); (b) transition between schools (e.g., S.M. v. State of Hawaii Department of Education, 2011); (c) transi tion services under Section 504 (e.g., Dutkevich v. Pennsylvania Charter Cyber School, 2011); (d) transition services but disposed of on threshold technical grounds, such as waiver (e.g., Hailey v. Matayoshi, 2011); (e) whether the parent is entitled to attorneys’ fees (e.g., T.F. v. North Penn School District, 1999); and (f) whether particular state regulations for transition services are valid under the IDEA (Baer v. Klagholz, 2001). The exclusions also extended to two oft-cited court decisions in which transition services were tangential to the respective case issues: Yankton School District v. Schramm (1996), which concerned eligibility of a student based on specially designed instruction in one handed typing and shorthand writing assignments, and J.L. v. Mercer Island School District (2010), which concerned the substantive standard for FAPE in the wake of the IDEA amendments.