The U.S. legislature began to recognize the rights of individuals with disabilities, which prevents schools from discriminating against special needs students. The US legislature laws demand that all of the rights be reserved for the rights of anindividual with special needs to have an appropriate education, even if the disabilities are not covered under the special needs law. The teachers and educators of special needs students remain accountable for the appropriate education of these students, and they will be held accountable in the court of law even if it means losing their job or locked up in jail. Schools started establishing programs for the learning disabled. Funding was provided for teachers to be trained in learning disabilities. The most important part of the Integration Phase is the Education for All Handicapped Children Act (PL 94-142) in 1975. This act was to ensure that all students no matter what type of problem they had would receive a "free and appropriate public education."( IDEA, Individuals with Disabilities and Special Needs Act).The last phase is the Current Phase, from the 1980's to the present. One of the major aspects of this phase is inclusion. Inclusion is educating students with disabilities in regular classrooms in their neighborhood schools, with collaborative efforts and support services as needed for each individual student. Another aspect of the Current Phase is when the EMA of 1975 was written as IDEA in 1990. IDEA, individuals with Disabilities Education Act, made it hard to suspend or expel student s with learning disabilities because of their behavior. IDEA also required that each learning disabled child have an IEP, Individual Education Plan. An IEP is a document that must include current performance of the student, the annual goals the students need to achieve, special education and related services. This Plan also included the child needs, participation, if any, with nondisabled children, modifications needed to take state test, dates and places of when and where special services will be provided and the measuring progress of the child, and any special accommodations that the child may need. Before a student can have an IEP, they first must be labeled as a student with a learning disability. The parents, special education teachers, the school guidance counselor, regular teacher, the school's psychologist, and the principle are always notified and included in the plans for this meeting.