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In Irving Independent School District v. Tatro (1984), the U.S. Supreme Court addressed the question of whether the related services provision of the Education of the Handicapped Act of 1975, now known as the Individuals with Disabilities Education Act (IDEA), required a school board in Texas to provide clean intermittent catheterization during class hours to a student who could not voluntarily empty her bladder because of her spina bifida. In holding that the board was required to provide catheterization, the Court reasoned that because this service was required in order for the child to remain at school during the day and that it was a simple procedure that could be performed in a few minutes by a lay person with less than an hour's training, ...

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