In the past, the disabled student faced educational challenges. In 1970, before the enactment of the Individuals with Disabilities Education Act, only one in five students with disabilities received an education from American public schools. Despite the lack of cost-effectiveness in "consigning disabled children to 'terminal' care in an institution," stereotypes regarding disabled schoolchildren persistently prevented educating disabled students in public schools. Thus, in enacting the Education for All Handicapped Children Act of 1975 (EHA), later renamed the Individuals with Disabilities Education Act (IDEA), Congress mandated an end to the long history of segregation, discrimination, and exclusion of children with disabilities in education. In advocating for the passage of the IDEA, Senator Hubert H. Humphrey (D-MN) argued "too often we keep children whom we regard as 'different' or a 'disturbing influence' out of our schools." Indeed, "special education and disabled children were often considered uneducable, disruptive, and their presence disturbing to children and adults in the school community." Congress intended the IDEA to be the vehicle for challenging these justifications for excluding students with disabilities.
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