When is "challenging behavior" too much? The rights of students with disabilities must be honored--but it can be a tough balancing act when behavior impacts the classroom.

Ten-year-old Bill Hutchison is in the fourth grade in Dickerson, Maryland. He has three brothers and sisters. He likes to watch the Disney channel. He enjoys playing his toy electric guitar. And this past February, his elementary school asked a judge to issue an order keeping him out of the classroom.

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According to court records, Bill--who has Down syndrome and ADHD--has bitten, struck, tripped, and attempted to strangle teachers and other staff members at his school, Monocacy Elementary, in the past year. After these incidents, Frederick County Public School officials took an unusual step: They applied for a 10-day restraining order to prevent the boy from entering the school.

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Court action was not his teachers' or the school district's first course of action. The decision turned upon the conflict between the school and Bill's parents about whether inclusion was working. School officials say no. They believe Bill would be better served in a special education school. Bill's parents, Michelle and William Hutchison, want their son to stay at Monocacy with a new behavior plan that plays on Bill's strengths.

While officials cannot comment on a case that is still before the courts, Pam Pencola, director of special education and psychological services in Frederick County says, "it's very rare that students are not able to have their needs met in an inclusive environment. We believe in providing a safe learning environment for all students and we're highly successful in most cases."

The Monocacy Elementary case highlights the delicate balance that teachers and schools must strike as they ensure the rights of students with disabilities to learn in the least restrictive environment while maintaining the learning community for the school as a whole. The issue is of growing concern, as more students with serious behavior issues are being placed in mainstream classrooms.

Many Children Have Benefited

Teachers and experts suggest that inclusion works best with the right supports in place: a school-wide emphasis on positive discipline, proper training, adequate funding, support in the classroom, and strong communication. Above all, shaping the behavior of all children rather than policing misdeeds can set the groundwork for successful inclusion.

Although disputes such as the one at Monocacy Elementary grab the headlines, inclusion has been a success for most. "The lawsuits, in the scheme of things, are few in number when you look at the millions who have benefited from these laws," says David Riley, executive director of the Urban Special Education Leadership Collaborative in Newton, Massachusetts. "This is challenging and culturally, we have a long ways to go."

Jonathan McIntire, a director of Exceptional Student Services for Orlando, Florida schools, agrees. "It's assumed that a lot of these kids are bad guys, but often the behavior is a manifestation of their disability." Schools with safety issues for children with disabilities often lack knowledge and resources, he says.

The Challenge of Inclusion

While most teachers and experts support the goal of inclusion, many are increasingly pushing for modifications, or "responsible inclusion"--especially when faced with aggressive or violent kids. "Special education has been its own worst enemy," says Ron Nelson, associate professor and co-director of the center for At-Risk Children's Services at the University of Nebraska in Lincoln. "We have pushed for inclusion, even though we don't know how to make it work."

Some kids' mental health needs are beyond what a general education school can deliver, says Nelson. "Schools have become the de facto mental health provider for children yet they are not set up for that." Through implementing a positive behavior model that emphasizes routines, clear expectations and proper supervision, most kids can be successful, says Nelson. But not all.

Diane Connell, professor of special education at Rivier College in Nashua, New Hampshire, agrees. Full inclusion isn't always the way to go, she says. While normalization is important, placing kids with disabilities in general education settings may not be in the best interest of the child when the classroom is not set up to meet the child's special needs. "Student needs should take priority," she says.

Phil Hatlen, superintendent for the Texas School for the Blind and Visually Impaired in Austin, says he has an aversion to total inclusion because it is a "one-size-fits-all" approach to education that doesn't take into account the diverse population of children with vision impairments.

"Responsible inclusion means the child goes into regular classroom with the skills needed to participate," he says.

A Teacher's Perspective

Pat Curtenbach is a teacher who knows how to develop those skills in the classroom. At Elliott Elementary School in Lincoln, Nebraska, five out of the 17 students in her fourth-grade classroom have special needs. Communication with the previous year's teachers and a strong special education team helps her manage the students' varying needs, from behavior disorders to learning disabilities to one who uses a wheelchair. While her 35 years as a teacher equips Curtenbach to handle her classroom's diversity, it is a lot for younger teachers to process and more training is needed, she says.

To keep behavior problems at bay, Curtenbach tailors her approach to the child's disability. For instance, for a student who is very concrete in his thinking, she will give him five tickets at the beginning of the day and when he is not on task, she asks for a ticket.

Being proactive with discipline policies has helped the school maintain a safe environment. "We respond clearly and swiftly to kids who aren't safe," she says. "If you are throwing things or hitting, it's immediately dealt with."

Students are told that being treated fairly doesn't mean that everyone is treated the same. So when students are disciplined differently because their behavior is a result of their disability, it is not an issue, she adds.

Creating a Safe Environment

Besides modeling, what can teachers do to create a successful, safe environment for all students? Plenty, say experts.

* SET CLEAR POLICIES. Many problems are preventable with a strong school community that emphasizes positive discipline, says Ron Nelson. Work with administrators and colleagues to set clear expectations and routines that everyone understands. Anticipate problem areas, such as line-up or lunchtime, and make sure there is adequate supervision. Have consistent consequences for inappropriate behavior and promote positive behavior. Research shows that discipline policies that reinforce good behavior are much more effective than punitive models, adds Riley. And communication is everything.

* ADOPT THE RIGHT ATTITUDE. Too often, teachers and other staff members underestimate the ability of students with emotional issues. "You have to assume all kids are competent and good," says Florida's McIntire. "When you hear the terms autism or emotional disability, some people have stereotypes they hold on to that might not be accurate. Get rid of the labels and see the child as a child."

* HAVE INFORMATION AT HAND. McIntire says that sometimes kids with behavioral issues transfer from one school to another and parents want them to have a "fresh start." So they don't tell the staff about the child's challenges. Then the child doesn't get the needed support and ends up acting out aggressively. "The best thing is to demand access to student files quickly and get information from the previous educator who had expertise on what did or didn't work," says McIntire. There is an assumption that there is an efficient exchange of information, but in fact the level of communication varies from case to case.

* KEEP EVERYONE IN THE LOOP. "Make sure everyone who works with the child is included in decisions," says Sue Masterson, a principal in Janesville, Wisconsin, and president of the National Association of Elementary School Principals. It's crucial that the parents agree with the plan and that they keep you informed about the behavior challenges of their child.

Nelson suggests that teachers need to identify and address the child's underlying problems. McIntire adds: "In most cases, if you understand the nature of the disability and the need of the child because of the disability, then you can structure the situation so the child doesn't behave poorly."

* HAVE A PLAN AND REVIEW IT. The team that knows and works with the student should develop a contingency plan for when aggressive behavior happens, says Rosemarie Young, a principal in Louisville, Kentucky, and past president of the NAESP. She advocates monthly team meetings to give progress reports and discuss the roles in serving some of the most challenging students.

"Suspension and expulsion should be our last resorts," says Skiba. "Schools should have the right to remove children who are dangerous to themselves or others. But it can be a crutch used in the absence of clear expectations, well-trained staff, school-wide rules, and preventive options."

* ASK FOR HELP. "Often the most difficult kids are put with the best teachers and that can ratchet up burnout," says Lisa Thomas, assistant director of educational issues at the American Federation of Teachers. Advocate for support personnel, paraprofessionals, and teacher mentors to assist yourself and other, more novice, teachers.

* SEEK TRAINING. "The behaviors I see are more challenging than in the past and teachers need training," says Masterson. "They need to know how to de-escalate a potentially volatile situation." This means training on body posture, choice of words, and more, she says.

* WORK IN PARTNERSHIP WITH PARENTS. Today's parents are more educated and equipped with information to lobby for the rights of their children with disabilities. "When you deal with our children, you are dealing with our hearts. Schools need to know that," says Sherri Trapp, whose 12-year-old son Tyler is autistic. "Our children are just as special as all the other kids."