Special education in the United States enables students with exceptional learning needs to access resources through special education programs. These programs did not always exist. "The idea of excluding students with any disability from public school education can be traced back to 1893, when the Massachusetts Supreme Court expelled a student merely due to poor academic ability". This exclusion would be the basis of education for all individuals with special needs for years to come. In 1954, Brown v. Board of Education sparked the belief that the right to a public education applies to all individuals regardless of race, gender, or disability. Finally, special education programs in the United States were made mandatory in 1975 when the United States Congress passed the Education for All Handicapped Children Act (EAHCA) "(sometimes referred to using the acronyms EAHCA or EHA, or Public Law (PL) 94-142) was enacted by the United States Congress in 1975, in response to discriminatory treatment by public educational agencies against students with disabilities." The EAHCA was later modified to strengthen protections to students with disabilities and renamed the Individuals with Disabilities Education Act (IDEA). IDEA requires states to provide special education and related services consistent with federal standards as a condition of receiving federal funds. IDEA entitles every student to a free and appropriate public education (FAPE) in the least restrictive environment (LRE). To ensure a FAPE, a team of professionals from the local educational agency and the student's parents to identify the student's unique educational needs, develop annual goals for the student, and determine the placement, program modification, testing accommodations, counseling, and other special services which meet the student's needs. Parents are supposed to be equal participants in this process as well as others that are knowledgeable about the child, the meaning of the data collected through the evaluation, and all placement options. The student's plan, to include the above items, is recorded in a written Individualized Education Program (IEP). The child's placement is typically determined by the annual assessment, based on the child's IEP, and as close in proximity to the child's home as possible. The school is required to develop and implement an IEP that meets the standards of federal and state educational agencies. The state department of education oversees its schools to make sure they are compliant to every student's IEP. If schools fail to comply to the child's IEP, the school district may