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The reliability of four measures of written expression was examined (total words written, mature words, words spelled correctly, and letters in sequence). Subjects included elementary-age students in several school districts, some of whom were learning disabled.

This court case established a three-part test to evaluate the adequacy of an LEA's program for ELs: First, is the program based on an educational theory recognized as sound by some experts in the field or considered a legitimate experimental strategy?