This article provides a systematic examination of the BOP in hearing officer decisions both before and after Schaffer. Part II examines the legal basis for the BOP both before and after the U.S. Supreme Court decision, resulting in the questions for this study. Part III explains the method used to collect and analyze the data, and Part IV presents the results that answer the specific research questions. Part V discusses those results and the implications of the findings for special education dispute resolution and provides recommendations for further study.
Cathy A. Skidmore and Perry A. Zirkel,
Has the Supreme Court’s Schaffer Decision Placed a
Burden on Hearing Officer Decision-Making Under the
35 J. Nat’l Ass’n Admin. L. Judiciary
Available at: https://digitalcommons.pepperdine.edu/naalj/vol35/iss2/1