School Health Services for Handicapped Children: The Door Opens No Further: <i>Irving Independent School District v. Tatro</i>, 104 S. Ct. 3371 (1984)

I. Introduction II. Background: The Education for All Handicapped Children Act and Supreme Court Interpretation Prior to Tatro ... A. The EAHCA ... B. Hendrick Hudson District Board of Education v. Rowley ... 1. The Court's Definition of "Appropriate Education" ... 2. Scope of Judicial Review of Educational Decisions ... C. Concerns of Educators and Parents after Rowley III. The Tatro Decision ... A. Administrative and Lower Court Action ... B. The Supreme Court Opinion IV. The Tatro Decision's Contribution to EAHCA Interpretation and Application ... A. Questions Answered by Tatro ... B. Questions Tatro Did Not Answer and New Grey Areas ... 1. "Meaningful Access" and "Some Benefit" ... 2. The Court's Conflicting Attitudes toward Schools' Financial Burdens ... 3. Reliance on State Medical Practice Statutes ... C. Smith v. Robinson V. Conclusion