Child Evidence

Physical restraint and seclusion in schools are disproportionately use · Child Evidence

special education / restraint & seclusion in schools

Physical restraint and seclusion in schools are disproportionately used on students with disabilities, carry documented risks of physical and psychological harm, and lack evidence that they improve behavior or serve any therapeutic or educational purpose; the science supports their use only as emergency last resorts to prevent imminent serious harm, not as behavior-management tools.

For the Court

Contested at the margins: consensus that restraint/seclusion harms and has no behavioral benefit, with debate only over the unavoidable-emergency threshold.

What This Claim Does NOT Say

Does not claim restraint/seclusion is never permissible; the consensus is that it may be used only as an emergency response to imminent serious physical harm.
Does not claim these practices improve behavior or have therapeutic/educational value; no such evidence exists.
Most harm evidence is from psychiatric/inpatient settings and observational school data; experimental school evidence is (ethically) lacking.
Does not establish injury risk for a specific program; rates vary by setting, training, and population, though disproportionate use is consistent.

Scope — Where It Holds

Federal civil-rights data show students with disabilities are restrained ~7x and secluded ~4x more than peers (Gage et al., 2020). Reviews of restraint/seclusion document trauma, PTSD (incidence 25-47% in psychiatric settings), distress, and dehumanization (Chieze et al., 2019; Cusack et al., 2018), and a critical school-focused overview finds injuries, deaths, inadequate training, and no evidence of behavior change (Ryan et al., 2026). A single-school EBD study reports low injury concentrated in few students (French et al., 2017), illustrating setting variation.

Sources & Verification

Seminal

Gage, N. A., Katsiyannis, A., Rose, C., & Adams, S. E (2020). National Trends and School-Level Predictors of Restraint and Seclusion for Students with Disabilities. Exceptionality.
Observational
Students with disabilities were seven times more likely to be restrained and four times more likely to be secluded than peers, and students in special-education schools were almost guaranteed to be restrained or secluded.
Bearing on this claim: OCR data: students with disabilities restrained ~7x, secluded ~4x more than peers.
doi.org/10.1080/09362835.2020.1727327

Supporting

Chieze, M., Hurst, S., Kaiser, S., & Sentissi, O (2019). Effects of Seclusion and Restraint in Adult Psychiatry: A Systematic Review. Frontiers in Psychiatry.

Precedent Bridge

Goss v. Lopez requires due process for school exclusion; the restraint/seclusion evidence — harm, disproportionate use on students with disabilities, no behavioral benefit — bears on the procedural and substantive limits of such aversive practices.419 U.S. 565 (1975)

Limits & Counter-considerations

Harm evidence is largely from psychiatric/inpatient settings and observational school data; experimental benefit evidence cannot ethically be generated; and injury rates vary by setting, training, and population even as disproportionate use is consistent.

Full Dossier

Last reviewed June 28, 2026