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Courts first acknowledge that student with EBD are being excluded from educational opportunities because of behavior issues.
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Honig v. Doe explained that congress "meant" to take the power from schools so that they could no longer exclude students with emotional disabilities.
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Congress amended IDEA stating there should be a school wide plan to address beavhior needs and also there should be a functional behavior assessment.
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Congress amended IDEA and finalized the Functional Behavior Assessment. Funds were provided for training to properly implement and carry out proper support for students with EBD.