New Article on Free Appropriate Public Education in the Circuit Courts

New on Westlaw: Lester Aron, Too Much or Not Enough: How Have the Circuit Courts Defined a Free Appropriate Public Education after Rowley?, 39 Suffolk U. L. Rev. 1 (2005). The article discusses putative conflicts in the circuits regarding the substantive standard for an adequate FAPE and the procedural question of who bears the burden of proof. The latter conflict, of course, was resolved by the Supreme Court this Term in Schaffer v. Weast.