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5. Bullying and Students With Disabilities
[ 779 F.Supp.2d 303 ]
|[ 779 F.Supp.2d 303 ]|
disability that creates a hostile environment." U.S. Dep't of Educ., Reminder of Responsibility Under Section 504 of the Rehabilitation Act of 1973 and Title II of the Americans with Disabilities Act July, 25 2000, available at http://www2.ed.gov/about/offices/list/ocr/docs/disabharassltr.html (hereinafter DOE Reminder of Responsibilities Letter). Studies have shown that students with a disability, whether it is visible or non-visible, are subject to increased bullying that is often directed at the disability. John Young, Ari Ne'eman, and Sara Gelser, Bullying and Students With Disabilities, in White House Conference on Bullying Prevention, at 74 (March 10, 2011), available athttp://www.stopbullying.gov/references/white_house_conference/index.html. These students are also at more risk for bullying directed at factors other than their disability. Id. at 77. Harassing conduct may take many forms, including verbal acts and name-calling, as well as nonverbal behavior, such as graphic written statements, or conduct that is physically threatening, harmful, or humiliating. DOE Reminder of Responsibilities Letter, supra.
[ 779 F.Supp.2d 304 ]
|[ 779 F.Supp.2d 304 ]|
and proficiencies needed to avoid and respond to bullying, harassment or teasing.