Manifestation Determination Reviews and Judicial Interpretations
A Systematic Review of Federal Litigation Challenging the Relationship Test
Bibliographic Data
| ID | 21376215 |
|---|---|
| Authors | Justin P Allen (0000-0003-0172-5970, Texas A&M College Station Texas U.S.A., corresponding author), Rachel J O'Neill (0000-0002-8589-4677, Sam Houston State University Huntsville Texas USA), Matthew T Roberts (0000-0003-0659-7138, University of Utah Salt Lake City Utah USA), Margaret E Trinka (0000-0003-4604-8029, Sam Houston State University Huntsville Texas USA), Kayla D Spenard (0000-0002-3020-8553, Sam Houston State University Huntsville Texas USA), Faith Fisher (0000-0001-8315-8492, Sam Houston State University Huntsville Texas USA), Ben A Mason (0000-0002-1614-6405, University of Missouri Columbia Missouri USA) |
| Year | 2026 |
| Volume | 63 |
| Issue | 3 |
| Pages | 618-630 |
| Publication date | 2026-03-01 |
| Open Access | Yes |
| Type | ARTICLE |
| Venue | Psychology in the Schools (JOURNAL) |
| Journal identifiers | ISSN: 0033-3085 • E-ISSN: 1520-6807 |
| Publisher | Wiley (PUBLISHER • GB) |
| DOI | 10.1002/pits.70113 |
| OpenAlex | W4414973031 |
| Language | EN |
| References cited | 24 |
The manifestation determination review (MDR) is a pivotal element in providing equitable access to education for students with disabilities. This systematic review examines litigation concerning MDRs with an explicit focus on federal challenges to the relationship test (i.e., Was the problem behavior directly and significantly related to the student's disability?). Of the 448 cases identified for review, 16 met the full inclusionary criteria. The findings revealed a spectrum of legal challenges encompassing the district's interpretation of the relationship test. Three overarching themes were identified: (1) cases in which the MDR was foundationally improper, (2) cases wherein the team failed to review the student's relevant records sufficiently, and (3) cases in which the scope of the disability's influence was improperly considered. The second and third categories encapsulated additional subcategories, delineating nuanced contentions. These results provide insights into the nature and scope of MDR‐related court challenges and how the courts receive them. The complaints identified in this study highlight ambiguity within the MDR process that results in opposing interpretations of the relationship test. The findings underscore the nuances of MDR procedures and provide decision‐making guidance for school psychologists, educators, and policymakers
Ambiguity · Element (criminal law) · Interpretation (philosophy) · Scope (computer science) · Test (biology) · Judicial and Constitutional Studies · Legal Issues in Education · Legal Systems and Judicial Processes
The well-built clinical question
How to Do a Systematic Review
Interrater agreement and interrater reliability
Updated methodological guidance for the conduct of scoping reviews
The Measurement of Observer Agreement for Categorical Data
The PRISMA 2020 statement
Three Approaches to Qualitative Content Analysis
| Highly cited | No |
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