The number of students identified with behavioral problems is a significant proportion of the roughly six million youths (more than 1 of every 8 students) who receive special education services in the United States (General Accounting Office [GAO], 2001; based on 1997 - 1998 figures). As students with physical disabilities are increasingly accepted in mainstream classes due in part to the inclusion movement, there is growing evidence that students with behavioral problems are filling the newly vacated special education spaces (Bielinski & Ysseldyke, 2000; Ordover, 2001). The exact number of students in special education programs due to behavior is not known, and may never be determined accurately given the limitations of research as well as the elasticity of the label "behavioral problem" (Best, 1994; Elkind, 1998; Liachowitz, 1988). When researchers from the General Accounting Office (GAO) attempted to collect national data on the placement of students in special education due to behavior, they found very little even after interviewing experts in the field and public policy advisers. Their own survey had a response rate that was too low to produce estimates that were nationally representative. However, based on their surveys and interviews, principals reporting on incidents of serious misconduct—including "violent behavior," "drugs," "weapons," and "firearms"—stated that 15.4 per 100,000 of the students involved in these forms of misconduct were in regular education classes; and that 49.5 per 100,000 were in special education programs—a misconduct rate that is three times higher for students in special education.

But even if accurate, these statistics can be interpreted in different ways: do these rates mean that students with disabilities have propensities to misbehave or that misbehaving youths are three times more likely to be placed in special education or that students who do not conform to school mores and rules are placed in special education with behavioral problem diagnoses? The article does not answer these questions definitively, for there are limitations to the research's generalizability since it was conducted just in one school. But the article does show how common institutional practices can potentially influence the placement of students with behavioral diagnoses in special education programs. The naming of a student as a behavioral problem depends not only on students' behaviors, but also on a diagnostic process that is used to identify youths as socially and emotionally disturbed (or with a serious emotional disturbance, both of which are referred to as SED), other health impaired (OHI), or with a specific disorder, such as attention-deficit/hyperactivity disorder (ADHD), anxiety disorder, pervasive developmental disorder, or dissociative disorder. In spite of criteria developed by the American Psychiatric Association (1994) and other distinguished groups to ascertain whether or not a student has a behavioral problem and to categorize the specific form of problem, these diagnoses depend on an interpretative process involving testing, categorizing, and placements, whereby judgements, professional intentions, prejudices, and policy matters influence the interpretation of what is and what is not a disability and who does and who does not have one (Biklen, 1992; Bogdan and Taylor, 1994; Brigham & Polsgrove, 1998; Goffman, 1963).

The article examines several aspects of the behavioral problem categorization and placement system. First, it draws attention to how policy (in this case the Individuals with Disabilities Education Act) influences school-based activities and beliefs regarding the identification and placement of students identified as behavioral problems. Then the institutional process of maintaining this system is examined in relation to divisions and animosities that influence the use of the behavioral problem label, decisions about who is a behavioral problem, and students' subsequent placements. These divisions and animosities were undercurrents during many interactions among professionals and youths and had a great and almost hidden influence on many youths' prospects for the future. Narrative data from field work and interviews describe some of the institutional dynamics involved when students were placed in special education programs, or were moved out of them, for reasons associated with their behaviors, and highlights how this process was, in part, an activity that tracked students based not on perceived academic ability but rather on perceived behavioral disability.

At one level, the article brings together information from a variety of sources to examine the institutional context of the behavioral problem categorization and placement system in one school. This aspect of the article draws attention to how the behavioral problem category of student was created and maintained often in ways that had little to do with the actual behaviors of students. Rather, the behavioral problem system was organized and used to meet the needs of a larger school system that was already set up in a way that categorized and separated students based on a variety of factors related to academic and behavioral abilities, as well as socioeconomic and racial identifications. At a broader level, the article also shows how the needs of professionals and the nature of institutions shape the goals of what professionals and organizations aim to achieve (see also Goffman, 1961; Skrtic, 1995). In regard to students with behavioral problems, they (along with their families) seek out education, but what they get are particular services; schools are built to educate students, but they provide programs. While many may argue that there is a logical relationship between the education that is sought and the services or programs provided, the research here directs attention to how these services and programs can, in fact, contradict the goals of education. Since our analysis dealt with dynamics that we have seen in other research, and in other schools where one of us has worked and the other has conducted research, it is likely that the issues raised here apply to other schools (Burstyn et al, 2001; Casella, 2001). While the focus is on one high school, at times we make more general comments about the topic based on patterns that were discovered when this study was compared to these other research and work experiences.

The focus of the article is on one school, which we call City High, where an ethnographic research project was conducted for two years. The research began as a case study of Mitch Page, who was at the time of the research a school social worker at City High. When I (the first author) began the case study, I was interested in understanding the daily work life of an urban school social worker. In addition to case study methods, I followed a process of qualitative research whereby the researcher presents research findings periodically to informants (in this case Mitch Page)—a process that Merriam (2002, p. 31) referred to as "member checks" (see also Bogdan & Biklen, 1998). When I presented various findings to Mitch Page, we began to discuss them, especially the issue of students being labeled with behavioral disorders. In time, Mitch Page became less a subject of the research than a co-facilitator. I broadened the scope of the research, and the activities that the school social worker was involved in became of greater interest than the job itself, especially those duties involving home visits, special education meetings in school, and mentoring and counseling sessions with students. Ultimately, the work presented in this article involved a joint collaboration, one initiated by the researcher, but influenced by the social worker. The conclusions are the result of agreements and also disagreements between us that had to be resolved through careful analysis of the research data and through our acceptance that what is stated here is partial—a well-informed interpretation of events during a particular time in a school's history.

City High is a small-city high school of about 3,000 students. The city of about 72,000 inhabitants is rather poor and has a large Puerto Rican community and many older Polish neighborhoods. About 69 percent of the population is White, 10 percent African American, and about 27 percent Latino (22 percent of whom are Puerto Rican). There are wealthy areas of the city, and Greek, Polish, and Italian working-class neighborhoods. City High is one of the largest schools in the state and is a sprawling building of additions that were made when the only two high schools in the city merged. The school is about 38 percent Latino (most from Puerto Rico), about 15 percent African-American, and about 43 percent Caucasian (many of Polish or Italian decent), and there is a small percentage of Native Americans and Asians.

The research at City High was conducted 2–3 times a week from September 1998 to May 2001 for about 2–3 hours each day. Though part of a larger research project, the data for this article involved: 86 observations with Mitch Page (during which I would accompany him for the time I was in the school); observations of 24 Pupil Placement Team (PPT) meetings; observations of 12 self-contained classes; observations of 2 faculty meetings of self-contained classroom teachers; observations of 2 discipline committee meetings; and daily hallway observations. The research also included interviews with 23 students placed in special education; 10 interviews with teachers who taught students in special education; interviews with the 4 assistant principals, the principal, the director of special education, 2 school psychologists, and multiple interviews of Mitch Page during the first year of the research. The research was conducted in a way that was as naturalistic and non-invasive as possible. Though some interviews were scheduled and tape recorded, most interviews were informal and conducted in classrooms, outside the school, and sometimes on the spur of the moment in the hallway during a teacher's break period. During my attendance at meetings, after requesting permission to conduct the research and to sit-in on the meeting, I tried to remain in the background. While Mitch Page was a participant in the research and a member of many of the PPT meetings at the school, he tried to not let the research interfere with his school duties. However, in spite of these precautions and our attempts at objectivity, no doubt the nature of our roles in the school (one who was an outsider and one an insider) influenced not only our access to meetings but also our interpretation of them. For this reason, the research does not provide a definitive answer to the questions posed earlier. Rather, the article is our well-informed perspective on the topic, which we attempt to clarify and support through our presentation of narrative data.

In addition to site-based research we studied court cases involving rulings about special education and discipline. We also analyzed policy referring to special education and school safety, especially the Individuals with Disabilities Education Act (IDEA). The topic of this article was derived from conclusions from the coding of all these data, including field notes, interview transcripts, policy documents, and law cases. As the coding was done, particular connections between misbehavior and special education arose. These codes included, "SED student," "acting out," "manifestation hearing," "PPT," "disability and discipline"—all of which were phrases that emerged in the data repeatedly. Certainly, in the data, there were instances when violence was a topic, but there was no mention of special education. There were also instances when special education was mentioned without reference to violence or safety. However, we identified many sections of data that contained information about disabilities and behavioral problems together; in these sections we coded more selectively, in a manner that Strauss (1993) called "axial coding," where one analyzes more closely the original set of coded data (see also Bogdan & Biklen, 1998). The research for the section of the article involving PPT meetings consisted of observations of 14 formal PPT meetings; another 7 that were informal in that they lacked discussion and were procedural (a paper needed to be signed or a placement for a student was continued for another year and all were in favor of that); and 3 that were canceled at the last minute (usually because a parent did not arrive) but provided us opportunities to talk to individuals who had intended to meet.

The institutional processes of servicing young people who are determined behavioral problems are influenced by laws and regulations related to discipline, placements, rights, and the types of services that are required by schools. The 1997 reauthorization of the Individuals with Disabilities Education Act (Public Law 105-17) was, in a part, a response to increased numbers of youths in special education programs due to diagnoses related to their behavior. The amendments focused almost entirely on discipline requirements for aggressive and misbehaving students, the placement and protections of students who are being disciplined because of their behaviors, and regulations involving students caught with weapons in school (General Accounting Office, 2001; Katsiyannis & Maag, 1998; Smith & Colon, 1998). IDEA defines disabilities to include a number of emotional and physical impairments, including mental retardation; hearing, speech, or language impairments; orthopedic impairments; serious emotional disturbance; autism; traumatic brain injury; other health impairments; or specific learning disabilities (Public Law 105-17, 1997). Along with its earlier version, Education for All Handicapped Children Act, IDEA includes what are essentially behavioral problems, especially in regard to "serious emotional disturbance" (SED) and "other health impaired" (OHI). These are diagnoses for children who act aggressively, are self-destructive, or possess one of several types of behavioral disorders (BD) or conduct disorders (CD).

IDEA defines serious emotional disturbance in a fashion that only hints at the possibility that the student labeled SED is aggressive or hostile; rather, the essence of the label is meant to identify students who appear detached, alienated, depressed, or suicidal. A "serious emotional disturbance" as stated in IDEA included five characteristics, one or more of which must be evident over a long period of time and to a marked degree and must have an adverse effect on educational performance. The categories include (Public Law 105-17, 1997; Ruehl, 1998):

An inability to learn that cannot be explained by intellectual, sensory, or health factors.

An inability to build or maintain satisfactory interpersonal relationships with peers and teachers.

Inappropriate types of behavior or feelings under normal circumstances.

A general pervasive mood of unhappiness or depression.

A tendency to develop physical symptoms or fears associated with personal school problems.

When acts of misbehavior and aggression in schools are viewed as manifestations of a serious emotional disturbance, special education ends up being a placement for students who are not disabled in the traditional sense, and not just those with a "pervasive mood of unhappiness or depression," but also those who are deemed hostile or potentially violent (Casella, 2001; Ordover, 2001). The protections that IDEA provides for these students (generally labeled SED or OHI) have been modified over time. Before the 1997 reauthorization of IDEA, a student with a disability could be removed from school for up to 45 days to an interim alternative educational setting for carrying a firearm. While this placed a restriction on the Gun-Free Schools Act, which stated that students should be expelled for no less than one year for the same violation, the 1999 regulations that were mandated two years after the reauthorization modified this provision. Under the revised law, students in special education programs who have been found with any weapon (not just a firearm), or possess, use, sell, or solicit drugs in school or at school functions, as well as disabled students determined by a hearing officer to be so dangerous that the student's behavior is "substantially likely to result in injury to the child or others"—these students too can be suspended for up to 45 days (General Accounting Office, 2001, p. 10). These out-placements can also be extended in 45 day increments if it is determined by a hearing officer that the student still poses a risk.

The 1997 reauthorization of IDEA provided safeguards to protect students in special education programs against disciplinary actions that would remove them from school, but these protections can be circumvented in cases involving students who are deemed by school professionals to be dangerous to themselves or others. In addition, due to special education law and the inclusion movement, most students desiring to be placed in regular education classrooms are free to do so. However, as Ruehl (1998) pointed out, in court cases that have supported full inclusion, the students were well-behaved and not considered a behavioral problem by school professionals. The first appellate court decision involving whether or not a child who was categorized with a "serious emotional disturbance" could be placed in special education against the wishes of the parents was decided in Clyde K. v. Pulyallup School District in 1994. In this case, the court ruled in favor of the special education placement after considering the academic and nonacademic benefits of regular education and the effects of disruptive behavior on other children and on the teaching and learning process. The case supported the right of administrators to keep students not only in special education, but in out-placements. This was true in spite of the "stay put" provision of IDEA, which states that students remain in school while their cases are being considered and due process is being applied.

For students with behavioral problems, IDEA is a weak protection device that gives much leeway to school administrators to use suspension and expulsion as standard disciplinary practice. How IDEA is implemented depends on the intentions of school professionals and particular circumstances in schools, but before even being implemented or interpreted, the policy is already opening doors that promote a second tier in special education programs. This second tier is comprised of students who, though not in regular education, do not receive the same protections as other physically disabled students in special education. Also, as was the case in City High, these are often youths of color and of low socioeconomic status. According to school records, of the 61 students in the 9^th grade identified as emotionally maladjusted in 2002 and in self-contained classrooms, all but 9 were students of color (though Caucasians comprised about 43 percent of the total school population): 25 were Latinos, 7 were Latinas; 7 were White males, 2 were White females; 5 were Black males, and 2 were Black females. Once identified with a behavioral problem, these students were treated not like students in regular education, and not like students in special education. They were a middle group that was pulled out of regular education but did not necessarily fit in special education, for they were given different types of laws, regulations, and as the next section points out, also different kinds of treatments than other disabled and nondisabled students. These results have little or nothing to do with the behavior of students, but rather with the institutional processes used to make decisions about them. The following section offers a glimpse at how decisions are made about youths and demonstrates how the futures of these youths are determined through a bureaucratic system that fosters animosities and divisions, and as such, offers little hope to young people once they are identified as a behavioral problem.

As mentioned earlier, statistics on the numbers of students in special education programs due to diagnoses related to behavior are scarce and where they do exist they are not clear or are limited, though data are being collected currently by researchers, the GAO, and other groups. Even with these statistics, though, the numbers would not reveal the dynamics involved in the placement and exiting of students in special education programs, or how people are determined to be one category of disorder and not another, or even what those categories mean. What these aspects of the topic represent is the daily work that goes into the process of identifying youths with behavioral problems, and the way this work is influenced by circumstances surrounding each case, including the type of violation (especially, whether or not the violation involved a weapon), the support that students have from family and/or school staff, how interpretations about behavior shape what professionals see as viable solutions to a problem, and the strategies that are employed in a school system to manage students (Ferguson & Ferguson, 1995; Hehir, 2002; Freire & Macedo, 2000). At the very least, these aspects of the topic show that the separation of students into special education programs due to behavior is far from a natural process or one that can be accounted for by objective diagnoses.

Despite the fact that criteria have been established to determine a behavioral disorder and professionals who test students have been trained to do so, there is much room for broad interpretations involving diagnoses. The identification of students as behavioral problems is done by people whose perspectives are cast within particular borders that are both literal (as in the borders of a school building) and professional, especially in relation to borders that separate professionals (the caretakers) from students (the clients) as well as one professional (counselor) from another (teacher). School professionals are also influenced by the everyday talk about behavioral problems that provides what Danforth and Navarro (2001, p. 186) referred to as a "narrative landscape in which to construct social situations and thereby take action." Essentially, diagnoses are part of professional and institutional practices involving the often mundane and routinized work of being a school professional, of language use and policy talk, and of decision-making processes, which constitute the work of both managing students and supporting the institution in which one works (Conrad & Schneider, 1980; Mehan, Hertweck, & Meihls, 1986; Taylor & Bogdan 1992).

These ground-level realities expose the interpretative and conflicted nature of diagnoses related to behavior. They were also referred to by the City High director of special education programs. She was a vivacious and conscientious director who did not teach classes, but seemed worn down by paperwork and meetings. Always busy at her desk, on the phone, trying to find someone, or on her way to a meeting, her job represented the bureaucracy of special education. She said that the meetings and the paperwork were meant to "nail down the process" and make it "clear and concrete." Almost in the same breath, though, she talked about its intangibility:

"They [the policymakers] will often change guidelines for determining special education. As they change guidelines you'll see that kids who don't qualify under one area may qualify in another. For example, I was with a psychologist from another building, and she said to me, 'I could qualify just about anybody under SED if I look hard enough.' And I said [to myself] that this child is going to wear that label until at least they get into the high school. When we would do a triennial to see whether or not the kid qualified, I sometimes wonder, 'Are we doing this, no matter what we decide to do, because of . . . what? Because someone [a student] could have been a pain in somebody's side."

Diagnostic determinations of who is and who is not a behavioral problem will always partly depend on relationships among students and school staff, changing policies and people's use and misuse of them, resources available for tending to students who "have been a pain in somebody's side," and other political, economic, discursive, and cultural considerations that influence bureaucratic systems. As the director indicated, decisions end-up being made, though not always consciously, within a system of guidelines, triennials, psychologists, and qualifications. Accompanying these are systems of testing, diagnoses, meetings, and file keeping, all of which are meant to be uniform and consistent for all students. However, not only are they not consistent, but being consistent can be a problem when sweeping uniform judgements streamline the placement of students in special education. As Skrtic (1991, p. 170) pointed out, professional bureaucracy is nonadaptable to the needs of individuals because it is premised on the principle of standardization. For the behavioral problem student, needs are overridden by the desire for institutional efficiency, and professional collaboration for the good of all children is undermined by a division of labor that is non-bending, and that designates professional roles (regular education teacher/self-contained classroom teacher) with certain categories of chores (educating general education students/teaching self-contained classroom students). While veiled as equal treatment for all, efficiency and this division of labor cause segregation not only among students, but among school professionals.

In a faculty meeting being held by teachers of the self-contained classrooms, the teachers griped about the conditions of their work, and one teacher talked about her disillusionment with teaching students with behavioral problems. What she said was reminiscent of the director's comments about the way diagnoses are contextual and take place within a bureaucratic system, of which the teachers are sometimes reluctantly a part.

"I know what the rest of the school thinks of us down here. We got the crazy, criminal kids, the retarded kids, we can't handle them, and we just make referrals to get them out of school. But look what we are dealing with—we got the SED, disabled, violent, the tech. ed, the dregs of the school. What do they want from us? And look at our facilities. We have classrooms half the size of a normal classroom. We all remember our literature from school. We put a bunch of rats in a cage and they go crazy. Perhaps we make these kids crazy. The problem we have here is that we are part of a system that forces us not to think of individual students, but to look at all of the students. We forget everything we learned in school, about giving attention to the individual student, and we see all these kids as problems that will not go away. They're like boomerangs. They keep coming back and coming back worse than how they were when we suspended them. The system is breaking down and we're part of it I think."

While there were other faculty who made similar complaints about their work conditions, most did not speak so plainly about their complicity in this unwieldy system. This teacher criticized and put down the school system as well as the students. Though the system may have been breaking down, the students, nevertheless, were still dregs. According to IDEA and most college special education textbooks, special education should entail collaborative efforts for inclusion of students and ongoing supportive relationships between teachers to assure students' successes. However, tension can sometimes develop between professionals and students, and between different teachers (the special education teachers "down here" and "the rest of the school") that undermine these intentions. Tensions can also develop between policies, practices and professional knowledge that, on the one hand, standardize and streamline the placement of students, and on the other hand, require teachers to consider circumstances and to examine all incidents on a case-by-case basis.

Ironically, what sustains this bureaucratic system is not efficiency. The process, in fact, is incredibly inefficient if what defines efficiency is the actual success of students. Rather, the system is sustained by divisions and animosities that exist among students and professionals that limit individuals' access to power and keep people in their place. For adults, these divisions are based primarily on status and professional titles (separating "sped" teachers from "reg. ed." teachers, for example), and for students, they are based on diagnoses, as well as racial identities and socioeconomic status, that assign students to different tracks, placements, and services. The manner by which divisions and animosities between individuals sustain institutional bureaucracies and influence the treatment of students was seen in the sentiment expressed by a self-contained classroom teacher, who was supportive of her SED students, and often remarked about how they were treated differently by school administrators. Her story highlighted the animosities that existed between students and how these tensions inevitably became not just animosities based on placement, but also on race and cliques. The incident involved one of her students and a student who played in the school band (and the father of the band member, who was also a teacher in the school).

The teacher of the self-contained classroom was walking with her students in the hallway and came around a blind corner and almost tripped on instruments that had been left in the hallway. She told one of the band members that he should move the instruments and the band member did so, but only moved his own instrument. The band member told the teacher that they had no place to put the rest of the instruments, and the teacher told him to put them in the band room, but the student told her that they needed to keep them out to practice. The teacher continued walking with her students, but forgot to tell several who were lagging behind to watch out for the instruments. What happened next was vague, but it appeared that one of the teacher's students kicked an instrument and was then called a "dumb-ass Puerto Rican" by one of the band members. At first, the teacher insisted that her student had not kicked the instrument, but then the student admitted that he had. But when he admitted this, he also told the principal and his teacher that the band student had called him a "racial slur." In the following excerpt from an interview with the teacher, the teacher described how the situation was handled:

"I think, my kids, I think all the kids in special education are just dignified. There's a label to them. I just had a run-in with a regular ed. student versus my student, and the father of the reg. ed. student, who happens to work here. Of course, it was my student's word against his—we had no chance. So the father of the student, who is a teacher here, and I get into an ugly battle. The father was like, 'My boy didn't do anything wrong, and I'm the father and I know the principal and so you little Miss Chicky can just go.' And that's really what it was. I thought it was over, but the father was still angry because he knew that my kid really did kick the instruments. But then we found out that there were threats made and there was a racial slur made from the band members to my guy. But nothing came of it because my guy couldn't identify who said it. They [the principal and assistant principal] called three of the band guys into the principal's office, and even I couldn't tell them apart. One of them had dark hair but except for that they could have been brothers. They all have the same hairstyle and those same glasses that don't do anything but are there for looks. I couldn't tell them apart either. One of them said "dumb-ass Puerto Rican" and Jose, my student, said something like, "I may be Puerto Rican but I'm not a dumb-ass Puerto Rican."

So the principal asked Jose, 'So what do you want to see happen to these boys?' And Jose said, 'Nothing. I just don't want to be called a dumb-ass Puerto Rican.' And so then they asked me, and I just said, 'Well, you know, just have him apologize if it happens again.' Fine, so the principal gets all the kids that were involved. Six of the band kids and mine, and he has them all shake hands and he said to the band student and my student, "Okay, shake hands now." And then he said to the band student, "You now have one new Puerto Rican friend," and then said to Jose, "And you have six new White friends." The assistant principal was there, and even she said to me, "Can you believe he [the principal] said that," and I was like, "No." She [the assistant principal] said the whole thing was white-washed, that's how she put it."

Many types of divisions are represented in this short description. They are based on placement, they are racial divisions, they are professional divisions, and divisions based on cliques and extra-curricular activities. Foremost, there is a division that is created between students with behavioral problem labels and those in regular education programs. There are also divisions between those in special education for behavioral problems and those in special education because of physical or learning disabilities, since all of these teacher's students were SED labeled. Considered in light of what the director and teacher had discussed in their earlier quotations, we see different types of tensions that are created within these various divisions: teacher advocacy for students at the same time that students are confined in self-contained classes and separated from the mainstream of the school with the use of behavioral diagnoses; tensions between school structures, especially those involving regular education and special education placements; and tensions between teachers of different professional stature and genders. If we were to consider the implications of these tensions, we would need to consider them in the context of not only informal interactions (as was the case in the previous field note involving a hallway happenstance) but also in the context of more formal interactions, such as PPT meetings, since this is where the actual placements of students in special education are determined. By taking what was discussed in this section and applying it to PPT meetings, the next section is a short examination of this IDEA requirement, highlighting an institutional process that ends-up a defining moment in many youths' lives.

PPT meetings are convened to determine the placement of students who are in special education, and at City High they were run according to due process and the regulations of special education law. While circumstances varied in meetings, it was common that students and parents were Latino or African-American, most involved boys, and in many cases the students were from working-class or poor families. On 3 occasions, an interpreter was needed for non-English speaking parents. In one case, the interpreter aided a Polish-speaking parent, and in the other cases a Spanish-speaking interpreter was needed. PPT meetings were convened for various reasons: to refer students for testing because of misconduct or threatening behavior; to change the placement of a student; and sometimes to determine if a student's misbehavior was a manifestation of her or his disability. As mentioned earlier, this is the result of special education law that requires a manifestation hearing.

The following two PPT meetings are examples of the ways students' placements are sometimes determined. The tensions and divisions discussed in the previous section were evident in these meetings, but so were other dynamics related to tracking, the influence of families, and the ease and naturalness of removing students from school when their violations involved behavior. The two field notes we chose because they involved a girl, who was Latina, and a boy, who was African-American, and were, to some extent, typical of the students who attended PPTs. The circumstances also involved two different outcomes. The boy got out of special education and his PPT meeting was requested by his grandmother. In the second case, the Latina was out-placed and the PPT was called by the school to determine if her weapon-carrying charge was a manifestation of her disability.

The first PPT meeting involved Barrie, who was described by his counselor as "oppositional." He was in special education because he was determined to be SED in middle school, a label which he carried over to high school. He was African-American, a city kid, and was usually in the hallways with his friends between classes. He rarely drew attention to himself (was not loud) and he did not cause serious trouble, but was known among teachers as annoying and defiant.

This was Barrie's second PPT meeting at the high school. At the beginning of the school year, upon entering 9^th grade, Barrie and his grandmother had had a PPT and had requested that Barrie be taken out of the self-contained classroom and placed in regular education classes. At the time, school staff convinced the grandmother that Barrie should remain in the self-contained classroom until the end of the marking period. It was not insignificant that the day of the current PPT, described in the following field note excerpt, was the last day of the marking period. The grandmother had arranged the meeting on the first day that she could. As in their first PPT, the grandmother wanted Barrie out of self-contained. The following is taken from field notes describing the meeting.

The PPT meeting was attended by the director of special education, a school social worker (Mitch Page), the student's counselor, the teacher of the student's self-contained classroom, a vocational education teacher, the assistant principal (the only African-American administrator in the school), the student, and the student's grandmother. The meeting was held, as usual, in the conference room in the special education department. The student, Barrie, sat very still at the head of the table looking straight ahead down the long table and at the wall across from him. His grandmother, who had requested the PPT, sat next to him. She was Barrie's legal guardian.

The director of special education started the meeting by stating the purpose of the PPT: "We are here to consider removing Barrie from his self-contained class." The grandmother nodded, and said, "Barrie will do better academically and behaviorally."

The counselor looked at Barrie's grades. He had good grades, a "B" in algebra, which was the only class he was taking in regular education. People around the table seemed surprised that he got a "B" in math.

The grandmother said, "He got good grades, but Barrie told me that he doesn't know how he got good grades because he doesn't do anything."

The director stated, "It's not that the teachers don't give him work to do, that he doesn't do anything, it's that Barrie doesn't always show the effort."

The social worker interjected, "He did well in the math, where he was mainstreamed. He has the brains."

The assistant principal said, "Brains isn't the issue. It's behavior. How many times do we tell you to take off that headband."

Barrie had a headband around his neck during the meeting. The assistant principal said, "I already have one of your hats in my office that I took because you were wearing it. Every morning you have to challenge us. You wear your headgear and just wait for a confrontation." She said, "I am willing to give Barrie a chance if he breaks the behavior pattern."

The grandmother seemed pleased with this last comment. But the director of special education provided a cautionary note: "Once Barrie is out of special education there is no safety net for him. The process is much faster to get bounced out." She explained, "He can do it academically. His grades show that. It's the other stuff that we worry about." The director then asked the grandmother, "Given this information, do you still want to withdraw him."

Without a moment's hesitation, and quite loudly, the grandmother said, "Yes."

Then the teacher of Barrie's self-contained classroom said, "I don't know why we are even considering this. Why is there the push to get him out of special education? Barrie told me that on November 30^th [two days away—the date of his birthday when he turns 16] he was going to drop out."

The grandmother said, "He's not dropping out." The teacher turned to Barrie and said, "What did you say to me?" Barrie mumbled, "If I don't get out of special ed. I'm dropping out." The teacher said, "That's not what you told me. You told me you were dropping out." The assistant principal interrupted and said, "If we put you in regular ed. will you put the hat and coat in your locker?"

Barrie said, "If I get a locker." There was quiet for a moment. The social worker said, "You don't have a locker?" And Barrie shook his head and mentioned a friend whose locker he used. [Later when I saw him in the hallway, he was with another student and both were putting clothing in a single locker.] The director said, "So you antagonize administration with that hat instead of just telling them that you don't have a locker. Barrie nodded. The assistant principal, in a huff, said, "You can also put stuff in my office, I already have your hat there." Barrie didn't respond.

The director began to conclude. She said, "At this time, Barrie will be exiting special education, he will be in all regular education classes, he will stay in House A so that the transition isn't too abrupt, and we'll get him a locker if one is available."

The assistant principal said, "We still have your hat." And Barrie said, "It's not my hat." The assistant principal looked at the group with a "see what I mean" kind of look. The director said, "He's like one of my kids [referring to her son]." The teacher, who seemed to resent the fact that he was getting out of self-contained, said, "What is going to be better in other classes that you are willing to drop out?" Barrie did not answer her.

At this point the counselor piped up and said that Barrie had taken an "interest inventory" which "tell us your interests." Barrie became defensive and said, "I don't remember taking that test." The counselor ignored this comment and said, "You scored high on 'office operations' and 'business' which means you like hands-on work." She suggested that he get into appliance repair. Again, Barrie denied taking the test: "I didn't take that test." The counselor seemed to want to reassure him. "It wasn't a test," she told him. "There's nothing to worry about, it just scans your interests."

The director took advantage of a break in the conversation to end the meeting and told Barrie that he should meet with his counselor to make arrangements for his transfer to regular education classes. The grandmother asked the name of the counselor and the director told her. She turned to Barrie and asked him if he remembered the name and Barrie nodded and walked out with his grandmother.

The point of this field note is not to indicate what is standard procedure and outcomes of PPT meetings; a single description can not do that. What it can do, though, is indicate the types of issues and interactions that enter into decisions about a student's placement and, hence, his or her identification as either a behavioral problem or a "reg. ed." student. Before moving on to the second field note involving the manifestation hearing, several issues involving Barrie's meeting could be discussed here in ways that would bring out certain dynamics that will be seen again in the second PPT. First is the dynamic of the school and especially inter-structural dynamics across schools, in this case, between middle school and high school. Barrie was a 9^th grade holdover. The labels he received in middle school were following him into high school. This is what the director of special education meant earlier when she talked about the way students "wear that label until at least high school."

Like so many high schools, City High's dropout rate was especially high in 9^th grade and most PPT meetings involved 9^th graders. With 770 students entering the 9^th grade the year that Barrie entered, their transitions were in many ways continuations of middle school. For those doing well in middle school that transition would entail usually good placements in the top high school tracks. In cases such as Barrie's, though, students arrived with labels that put them in places where they would rather not be and where their chances for success were limited. It seemed to us that his way of dealing with this was to threaten to drop out, which came as no surprise to school staff (though it may have been a surprise to the grandmother). As the self-contained classroom teacher said, "I don't know why we are even considering this . . . Barrie told me that [on his 16^th birthday] he was going to drop out."

Many staff saw students' dropping out as a kind of irrevocable fact of life. The dropout rate at the school was about 30% according to school records, but this is a questionable statistic, as are most reports on dropout rates, for the numbers can not capture the gray areas between dropping out and being in school: for example, instances when students had up to 60 absences but had not officially withdrawn from school, or instances involving those who were out-placed, therefore not officially counted as a dropout, but were not attending their outplacements. Given these dynamics, Barrie was no doubt on the verge of being a city casualty. For him, the risk factors were piling up: he was African American, being raised by his grandmother, he was poor, and he was in (and now out) of special education, and was a freshman in a school with a significant dropout rate, especially in the 9^th grade.

Another important element of this PPT meeting was Barrie's grandmother. She was the first person to bring up behavior and in doing so said exactly what she needed to say to the director of special education: "Barrie will do better academically and behaviorally" out of special education. It seemed that she knew the conversation was going to be about Barrie's behavior. After saying this, talk turned to the fact that Barrie had good grades in mathematics, which the grandmother highlighted and used as a way to state her complaint: "Barrie told me that he doesn't know how he got good grades because he doesn't do anything." While the director interpreted, or wanted to interpret, this to mean that Barrie did not show effort (hence, "doesn't do anything") the grandmother had a different view. She was giving public face to what researchers have identified as a problem in some special education programs: that they become part of a tracked school system, and as the lowest track, suffer from low academic standards, racial isolation, and poor pedagogy (Garbarino, Brookhouser, & Authier, 1987; Kliewer, 1998; Smith & Colon, 1998).

That the grandmother had asked for a PPT meeting the moment Barrie entered 9^th grade demonstrates how the determination of a parent or guardian is sometimes needed in order to have students moved into regular education classes and to be considered in high school without the labels received in middle (and sometimes elementary) school. This incident demonstrated what Oakes (1995; also Oakes and Guiton 1995) has shown in regards to tracking and Lareau (1989) has shown in relation to school success: that parent awareness, social and cultural capital, and parent or guardian willingness to make a stand and advocate for their children sometimes against the recommendations of school administrators can be the most influential aspects of a young person's career in school.

However, it is also possible that the grandmother was inadvertently carrying out the will of the school, for Barrie's movement out of special education may make it easier for school administrators to remove him from school. The director of special education warned the grandmother: "Once Barrie is out of special education there is no safety net for him. The process is much faster to get bounced out." Though limited, the regulations of IDEA do provide some checks on school procedures when attempts are made to have students suspended, expelled, or out placed. Once out of special education, it will not only be easier for school personnel to get him "bounced out," but if he drops out of school, the school is less likely to be held responsible for not providing an adequate Individualized Education Plan (IEP), which is a requirement for students in special education programs, for the school will no longer be required to have one for Barrie.

That the grandmother's goal did not come to fruition until the second meeting, but that Barrie was taken out of special education eventually (that he had in some sense shed his behavioral problem label, though certainly not completely) shows how diagnoses not only entail broad criteria, as noted earlier, but are also part of a social interaction between professionals, young people, and parents or guardians, where animosities and divisions and sometimes alliances shape social interactions. In these cases, histories sometimes collide (as they did with Barrie and the assistant principal, who could not say enough about Barrie's hat in her office), contradictions arise (that Barrie, who was in special education, was doing well and in some cases excelling in school), and defiance was common (in Barrie's behavior and to some extent in the behavior of the assistant principal and the teacher of Barrie's self-contained classroom), and cultural identities shape interactions and loose patterns of behavior. This last point emerged in many ways. For example, the director of special education drew on experiences raising her own son to explain away Barrie's behavior toward the end of the meeting, and in some ways allied herself with Barrie. Cultural identity and defiance became mixed, as well, as the point about Barrie's use of headgear made evident. Later in the day, after the PPT, Barrie was in the hallway with the headband around his head again, though he had been reprimanded for this only two hours earlier. During the PPT meeting he had put the headband around his neck—he had not "worn" it but neither had he taken it off—which was yet another act of resistance that was defiant enough to draw attention but subtle enough to escape punishment. That so much school security policies involve clothing, headgear, backpacks, and other accessories, and that these are so much a part of youths' popular culture and acts of defiance, makes for a situation where so much control, power, and resistance can revolve around things like Barrie's headband and the hats in the assistant principal's office.

In the second PPT meeting, the factors that were important in Barrie's meeting—the support of his grandmother and that his violation did not involve weapons but rather headgear—were not existent. This PPT was called for Lynda, a Latina 9^th grader, who was also labeled SED and had in the past threatened suicide. Lynda had been caught in school with three knives. One of the knives was under the four inch limit (which identified them as a "deadly weapon" according to school policy), but the other two knives had blades longer than four inches. After being caught, she was suspended for ten days. In the meeting where her suspension was determined (which was attended by Lynda, her mother, the school police officer, and an assistant principal) she said that she carried the knives for protection. The mother had remarked that this was "understandable." Later in the meeting, Lynda said that she always carried them, and to this, the mother remarked, "that's possible. Her father taught her like that. She goes out at night."

Having completed her suspension, Lynda was now attending the PPT meeting so that faculty and staff members in the special education program could determine Lynda's placement. Like Barrie, Lynda was in the 9^th grade. She was a small, 15 year-old girl with a strong urban accent. With 778 students in the 9^th grade, Lynda had a 1.54 GPA and was ranked 354 in her class. Her mother attended the PPT, and like her daughter, she was a small Puerto Rican. She was about thirty-five years old and did not speak English very well. She also seemed timid and intimidated in the meeting. After the meeting, Mitch Page referred to this when he stated to me, "Part of this job is ugly. Imagine what it would have been like to be the mother sitting there. Talk about intimidated. She doesn't have the know-how, the background, the professional demeanor. She has a messed-up kid. And once again, where's the father?"

Before the PPT meeting, the group looked through Lynda's file and made the decision that Lynda could not be readmitted. The PPT, which was a manifestation hearing, was a simple formality. Talking among themselves about Lynda's file, the director remarked to the group, "There is no way that these knives had anything to do with her disability," and all agreed. In the PPT meeting, the girl's counselor, who was from the Dominican Republic, was especially harsh when she spoke to Lynda's mother. The counselor and the mother were both about the same age, Spanish-speaking, but their social classes were very different and it was possible that prejudice between Dominicans and Puerto Ricans was adding to the counselor's surliness. In addition to Lynda and her mother, the PPT was attended by me, Mitch Page, the director of special education programs, Lynda's counselor, and the teacher of Lynda's self-contained classroom.

The director began the meeting by introducing the school staff to the mother, who seemed to understand but was unable to remember all the names and titles, in part because she did not understand English very well. The director then explained the purpose of the meeting to those around the table: "We are here to determine whether or not Lynda's violation was a manifestation of her disability when she brought three knives to school." She said this while reading it from a sheet of paper.

She looked up from the papers and turned to the mother and said, "Lynda could be expelled for 180 days."

The mother answered very quickly, "Lynda is in special education. I know that." The director nodded, knowingly, and seemed to back-pedal. She said, "Lynda can be suspended for 45-180 days." The mother seemed to be satisfied with this response; she nodded, and seemed pleased that she had caused a bit of a stir and forced some form of correction.

The director turned to the group and said, "Our job has been to determine if her bringing the knives into school was a manifestation of her disability and we are in agreement that it is not." The mother did not protest. The director then said that Lynda would go to a mental health center, a clinic that provided educational services.

As soon as the director said this, the mother said, "I don't want Lynda going there. She was there before and became terrible. She'd come home in a terrible way. All the wrong people are there and it is a bad place with bad influences. It is a place for kids who have done things bad."

The counselor guffawed and said to the mother, "But Lynda did do something bad!"

The mother became quiet, but looked at the counselor with a blank face. It seemed that she was about to say something to the counselor, but the director said to the mother, "You need to understand. We want you to know that we have placed kids there for less."

The mother quickly resigned herself to the fact that Lynda did not have a chance of being readmitted to school. The mother asked, "Can she have a tutor?"

The counselor said, "Absolutely not. That is for kids who have to be home. There is no reason for Lynda to stay home."

The teacher of Lynda's self-contained classroom was a young teacher and seemed to like Lynda. She asked, "Why not? Why can't she have a tutor?" The people at the table ignored this comment, except for the mother who looked at the counselor for an answer. The teacher repeated herself: "Why can't she have a tutor?" The mother's face seemed to brighten for a moment. But the director told the teacher "We need the least restrictive environment, not a tutoring situation." The counselor told the teacher, "We have to understand that Homebound is for students who must be home." She slapped the table to punctuate the word "must."

The director said, "Lynda will go to [the mental health clinic] until the end of the school year, then we'll reconvene the group in September to determine a placement." She seemed to be trying to end the meeting.

But the mother, following-up on her earlier protests, again stated, "I don't want Lynda in [the mental health center]." She tried to explain her situation, pleading her case: "You see, Lynda is a follower. She is not a leader. I know that she will have problems if she goes there." She ended with a plea to them, asking them, "What can I do? Tell me what I can do?" Nobody answered her and she saw that the meeting was over, something that could be sensed in the quiet around the table. The counselor gathered up her papers. The mother asked how long the classes at the mental health center were and the director told her that there were two programs: one 8 a.m. to 10 a.m., another 10:30 a.m. to 12:30 in the afternoon. The mother said, "That is not a lot of time. She will be home a lot."

Not really responding to this concern, the director said, "The time for which she was suspended does count towards her expulsion. We will reconvene in September, but our report must go to administration and there might be cause then to suspend Lynda for 180 days."  

The mother seemed completely baffled. The director seemed to suggest that Lynda was going to be expelled for a year, but this was not clear. Nobody said anything and the mother did not question the director. The meeting ended as everyone got up to leave.

Like Barrie, Lynda was in the 9^th grade, but unlike Barrie she lacked certain advantages. Lynda's mother could not influence the outcome of the PPT meeting as Barrie's grandmother had. This was partly because Lynda was found with weapons, therefore school personnel, especially the director of special education, were responding to the deep concern about weapons in the building and drawing on IDEA policy that enables them to out-place students found with weapons; to a great extent zero tolerance policy overrides the protections of special education policy when violations involve weapons. We were not able to determine the details of Lynda's background, nor were we able to interview her, but her circumstances were familiar enough to recognize that Lynda was in the process of having her education withdrawn from her. The people at Lynda's PPT meeting knew that it was very possible that there would not be another PPT meeting in September with Lynda and her mother. One person attending the meeting remarked that the mother probably would not request a meeting. They knew that Lynda was likely to drop out or to slowly fade out of school through further expulsions or simply by not attending her outplacement at the mental health center.

Lynda was a young woman in a poor family, new to the United States (she was born in Puerto Rico), and in a poor city where she was involved in conflicts and potential violence that would be difficult to avoid even for the most capable of students. She was probably carrying weapons to protect herself not from strangers but people she most likely knew, lived near, and saw often; probably girls her own age, who, like other poor Latinas in the city, were involved in fights over boys, respect, material things, and sometimes issues involving babies. In this snapshot of her life at a particularly important moment in time, Lynda and her mother watched as their rights waned and Lynda was placed in a program that the mother already knew would be detrimental to her. We agree that the carrying of knives to school is a serious offense, but we have also felt that the withholding of a proper education is a punishment that exceeds the nature of even this crime, especially when the crime is viewed in the context of Lynda's life, where weapon-carrying is promoted even sometimes by parents who fear for their children's safety. There are also differences between carrying knives and threatening to use them, as well differences between those who have been violent in the past and youths like Lynda who have been more detached than dangerous. But it did not seem that the institutional process employed in Lynda's case promoted considerations of these circumstances. Rather, decision-making processes were done swiftly according to policy statements, not life circumstances. Also working against Lynda was the fact that out-placement institutions that needed to be filled have already been developed for students like her, and that various divisions of labor enabled individuals to make such crucial decisions about her life without taking ultimate responsibility for them.

There is an institutional process here that deserves great attention, for, at the time that the process is happening, it may have more bearing on a youth's life than any other process or influence. While students discussed in this article were in many ways supported by laws and policies, their rights waned if their violations were related to behavior, especially if the poor behavior was the carrying of weapons, as in Lynda's case. Other students who did not carry weapons, such as Barrie, were also assigned their placements in special education because of judgements about their behaviors. What these two cases reveal is how the behavioral problem label is used to explain a range of actions—from nonconformity to weapon-carrying—and secures placements that are often racially and socioeconomically segregated. These placements are seen as deserved, and even well-intentioned interventions that provide for the special needs of students with behavioral disabilities—and it is even possible that individualized attention is what these youths need—but the services provided here have little to do with the youths' needs and rather than maintain order, they seemed to create disorder in the form of divisions, animosities, and conflicts that arose almost naturally when institutional processes created hierarchical categories of people. There were obvious animosities between students in special education classes and those in regular education, and since the placements were mostly (though not entirely) separated according to race, socioeconomic background (and to some extent gender), these animosities converged along lines of not only ability and disability, but also according to identity. The inclusion movement has been a powerful force in education, and IDEA has spearheaded the movement. But, as we have tried to point out in this article, for students who have been identified with behavioral disabilities, a host of factors converge that can create a situation that may not have been anticipated by those who established the discipline and placement criteria for IDEA.

Though there is no way to predict what will happen in decades to come, reauthorizations of IDEA are likely to entail highly contested debates about discipline, disproportionality involving poor people of color in special education programs for reasons associated with their behavior, and the adequacy of special education in light of its high cost. This article is meant to give context to the decisions that will take place. Though in different ways, many schools are influenced by the types of school structures, institutional processes, and social interactions described in this article. What should be noticed here, at least from our point of view, is the way that these school structures, institutional processes, and social interactions influenced diagnoses and placements of young people based on behavioral categorizations. Young people have little control over these aspects of their placements, for they can not impact the elusive nature of diagnoses related to behavior, the influence of social contexts and professional systems on their placements, and the divisions, animosities, and in-school segregation that are already built into the school even before they arrive. These everyday organizational dynamics constitute the ground-level workings of school policy implementation, and though carried out in routinized ways the actions involved—the face to face encounters, the meetings, the happenstance experiences, the formal and informal rituals—often have great bearing on young people's lives.

While much of what happens to young people depends on their behaviors and actions, there are strong institutional processes creating obstacles that sometimes label, track, and segregate young people. At times, young people like Lynda are stripped of their school status as punishment for poor behavior. Other students must surmount obstacles with the help of strong parents or guardians, as was the case with Barrie. And yet, Barrie's entry into regular education will remain difficult not because of what Barrie has done or not done (or will do or not do), but because his movement into regular education is contradictory to the organization of the school, which is already structured to maintain divisions and to contain (or self-contain) students like Barrie. Ultimately, students like Lynda and Barrie are pitted against other students, they must fight for a seat in regular education, and are compared to those who come to school with many more advantages in life and in school and fewer obstacles all around them.

The placement of students in behavioral problem classes and sometimes in separate areas of the school (as was the case at City High) is a way of tracking students. But unlike basic tracking, which is purported to be based on academic ability, this form of tracking is based on behavioral disability, an even more elusive category of personhood. In both circumstances, though, testing and the judgements of professionals legitimize and officiate youths' placements, and in both cases, the academic and behavioral tracking of students invariably leads to racial and socioeconomic divisions. Though our perspective on the issue is shaped by many factors, and there are limitations to the research, it is possible that these labels have been developed in order to legitimize a renewed form of segregation that though not based on race and social class ends-up having the same result.

Earlier, a question was raised about higher rates of misconduct in special education programs, and a similar question could be posed here in relation to race and class. Do African-American and Latino youths misbehave more or are they more quickly identified as a behavioral problem than more fortunate youths? As several researchers have pointed out, it is possible that poor minorities are involved in more conflicts than their more fortunate counterparts, especially when their lives are enmeshed in community and school confrontations that can cause frustrations and resistance to school to boil over (Casella, 2001; Sampson & Laub, 1993; Tonry, 1995). But we have also seen a side of this issue that has more to do with what adults in schools are doing when they state that they are only following procedures or conducting meetings according to policy. There is a highly complex dynamic involved in these routinized procedures, for they not only provide or deny services to young people, but guarantee that the organization for which professionals work continues to function for the benefit of those who are already benefiting from it.

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