At issue in Timothy W. v. Rochester, New Hampshire, School District (1989) was whether a school board was required to provide special education services to any students with disabilities regardless of the severity of their disabilities. In deciding that a board had to provide services, the First Circuit found that officials may not refuse to offer special education services on the basis that children are so severely handicapped that they are incapable of benefiting from special education. This now well-established rule from Timothy W. is commonly referred to as the “zero reject” principle.