Many notables, such as Pearl Buck, Roy Rogers and Dale Evans,
and later the Kennedys, had begun sharing publicly the tribulations and
triumphs of life on a daily basis with the physically and mentally chal-
lenged.

As early as 1955, a year after the famous Brown v. Board of Education
decision, the Council for Exceptional Children's journal made a case for
ending the segregation of the disabled. National advocacy organizations
became stronger, hiring lobbyists who had a significant impact on the
thinking and political behavior of policymakers in Washington, D.C.

Despite these apparent gains for the cause of equity and accommoda-
tion for the disabled, writers put the total number of school-aged children
served in the 15 to 20 percent range as late as 1963. Many children with
intelligence quotients (IQs) measuring below 50 were still considered "train-
able" rather than "educable." It meant that since they could be trained to
accomplish only such life skills as feeding and toileting themselves, they
should be placed in a segregated training institution apart from the edu-
cable children who could benefit from traditional classroom education.

A few states and many individual schools made serious strides in
mainstreaming free of government mandates, but it was undoubtedly the
two class action cases that brought rapid change.

The Mills v. Board of Education of the District of Columbia and PARC (Penn-
sylvania Association for Retarded Children) v. Commonwealth of Pennsylvania
cases of the early 1970s laid the foundation upon which our current spe-
cial education law has been built. These cases represented successful ef-
forts at challenging segregated, inconsistent, or nonexistent programs for
educating disabled children. They brought state practices under federal
judicial scrutiny with an appeal to the Fourteenth Amendment's due pro-
cess and equal protection clauses. These cases represented an action ("class
action") not only on behalf of a few isolated, disabled students, but for an
entire class of disabled or exceptional students. As the court determined
in the Mills decision, the plaintiffs were eligible to "[s]ue on behalf of and
represent all other District of Columbia residents of school age who are
eligible for a free public education and who have been, or may be, excluded
from such education."

Plaintiffs' demands included (a) a free appropriate education, (b) an
Individualized Education Program (IEP), and (c) due process procedures.
One of these cases was settled out of court. In terms of results, plaintiffs

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