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Children with behavior disorders are deemed as having an emotional disturbance (ED) by the federal Individuals with Disabilities Education Act (IDEA), which provides that children and youth with disabilities have access to a free, appropriate public education. The definition and criteria for ED are found at 34 C.F.R. § 300.8(c)(4). ED is described as a condition with

one or more of the following characteristics over a long period of time and to a marked degree that adversely affects a child’s educational performance:

An inability to learn that cannot be explained by intellectual, sensory, or health factors.

An inability to build or maintain satisfactory interpersonal relationships with peers and teachers.

Inappropriate types of behavior or feelings under normal circumstances.

A general pervasive mood of unhappiness or depression.

A tendency to develop physical ...

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