In the Cerra v. Pawling School District case, the court noted that “when a learning- disabled child is in a mainstream class, ‘the attainment of passing grades and regular advancement from grade to...

In the Cerra v. Pawling School District case, the court noted that “when a learning-

disabled child is in a mainstream class, ‘the attainment of passing grades and regular

advancement from grade to grade’ will generally constitute evidence of satisfactory

progress.” Other courts have ruled that these factors are just issues to consider and not

necessarily determinative of progress, particularly when the student’s grades are

modified. What weight should a court place on student grades and the fact that the

student is passing from grade to grade? What kind of information may show that a

student with passing grades is not making satisfactory progress under the IDEA?