Kirsch-Goodwin & Kirsch's recent Arizona due process decision: A charter school that failed to offer a student FAPE in her IEPs is responsible for the student's placement at an out-of-state Residential Treatment Center (RTC).
http://www.azed.gov/special-education/files/2013/06/hearing-decision-13-005-flagstaff-arts-leadership-academy2.pdf.
Note, the law requires a student to be in the "least restrictive environment" (LRE), and for some students, the LRE may be an RTC.
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