Removal day eleven is where compliance gets expensive. In this webinar, we will share what the law actually requires during manifest determination and what to do when you don’t have the staff to deliver it.
The session features two viewpoints: a school law attorney’s legal read and a former district administrator’s on-the-ground experience.
What you’ll learn during this webinar:
- How disciplinary removal days accumulate, and where districts most often lose the count
- What a manifestation determination review has to establish, and what the record should show afterward
- Which services continue to be owed once a student is out of the classroom
- When compensatory education becomes a consideration, and how staffing shortages are treated
- How to build a recovery plan when services have already lapsed
A three-day suspension has a way of becoming a pattern.
A few more incidents, a couple of shortened days, an informal send-home that nobody logged, and before anyone realizes it, the district is past the ten-day threshold and decisions have already been made that are hard to unwind.
By that point, the law’s requirements are well established. What it looks like to actually meet those requirements, with the staff a district has on hand in the middle of a school year, is a harder conversation. Services owed during a removal are often counseling and behavioral supports—the exact roles districts struggle most to fill.
This session pairs a school law attorney with a former district administrator to walk through both halves.
Cassie Black covers what the Individuals with Disabilities Education Act (IDEA) requires: how removal days count, what the manifestation determination review must establish, which Free Appropriate Public Education (FAPE) obligations continue, and where compensatory education enters the picture. Brandy Samuell takes it from there — what documentation holds up under scrutiny, and how teams sequence a recovery plan when more than one student is affected.
Manifest Determination Webinar Speakers
Cassie Black, Esquire | Partner, F3 Law
Cassie spent 17 years in Illinois school districts as a school psychologist, assistant principal, director of student services, and assistant superintendent of curriculum and instruction before entering legal practice.
She now advises districts on special education and student matters, including discipline, due process, IEP meetings, OCR investigations, and behavior assessment and intervention plans.
She contributed to the 2025 edition of Special Education Due-Process Litigation for the Illinois Institute for Continuing Legal Education and holds a J.D. magna cum laude from Loyola University Chicago.
Brandy Samuell, M.Ed.
Brandy has 32 years in public education and has worked in nearly every role in it, from classroom teacher to assistant superintendent. Her experience spans general education, special education, mental health supports, and school turnaround across charter, rural, suburban, urban, and virtual settings.
She holds a M.Ed. in School Counseling from Texas Christian University and a B.B.A. in Marketing from Texas Tech University, with post-master’s work in Educational Diagnostics and Educational Leadership from the University of the Southwest. At eLuma she leads mental health and related services.
FAQ
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1. Who should attend?
Special education directors, student services directors, school psychologists, behavior specialists, MTSS coordinators, and district administrators. Anyone involved in disciplinary decisions for students with IEPs will find it relevant.
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2. Will a recording be available?
Yes. Register and we'll email you the recording after the session, whether or not you attend live.
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3. Will slides or handouts be available?
Yes. Registrants receive the slides and a other resources after the session.
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4. What is a manifestation determination review?
A manifestation determination review is a meeting the IEP team must hold when a student with a disability faces a disciplinary removal that constitutes a change of placement. The team answers two questions: whether the behavior was caused by, or had a direct and substantial relationship to, the student's disability, and whether the behavior was the direct result of the district's failure to implement the Individualized Education Program (IEP). If the answer to either is yes, the behavior is a manifestation of the disability, and the removal cannot proceed as it would for a student without a disability.
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5. What happens after 10 days of removal?
Once disciplinary removals exceed 10 cumulative school days in a school year, the district must continue to provide services that enable the student to participate in the general curriculum and make progress toward IEP goals. The obligation does not pause because the student is out of the building, and it does not pause because the district is short-staffed.
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6. Does a staffing shortage change what a district owes?
No. The obligation to provide FAPE does not adjust for vacancies. What a well-documented staffing shortage can affect is how a district's efforts are viewed and what a reasonable remedy looks like — which is why contemporaneous documentation during an unresolved vacancy matters so much.