." (Citing Board of Educ. denied, 475 U.S. 1140, 106 S.Ct. the contractor who provided the bulk of defendant's student transportation Sec. Over a dissent, this court held that sections 34-84a and 24-24 "confer[red] the status in loco parentis in nondisciplinary as well as disciplinary matters" on teachers (63 Ill. 2d 165, 172), and therefore *169 teachers were immune from liability "for negligence arising out of `matters relating to the discipline in and conduct of the schools and the school children'" (63 Ill. 2d 165, 173); only wilful and wanton conduct destroyed educators' immunity. Abeyta, 77 F.3d at 1258.

*. Although we are not called upon to decide whether all violations of EAHCA's procedural requirements are to be assessed according to a separate test of prejudice, we are of the opinion that inquiry is proper here, since the only error was one of technical noncompliance which did not result in any substantive deprivation. 9-103(b)). If the use of force can be understood as part of an attempt to accomplish some legitimate educational objective, such as discipline, classroom order, or learning itself, it is "capable of being construed as an attempt to serve pedagogical objectives." 20 U.S.C. Plaintiff argues that the term refers to the IEP in its original agreed upon form before its attempted revision. In this case, however, a dispute arose after the original agreed upon IEP was developed and officials sought its revision even before it was implemented. The question which was before the district court, and which we now consider de novo, is whether the Board's IEP, which provided for five hours of home instruction per week, is reasonably calculated to enable Emily to receive educational benefits. *309 James W. Coffey, of Chicago (Frank S. Righeimer, John T. Mehigan, and Robert E. Harrington, of counsel), for appellants. 1790, 90 L.Ed.2d 336 (1986); Geis v. Board of Educ. We conclude that the only logical position, under Rowley and general principles of administrative law, is that federal courts are required to defer to the final decision of the state authorities, in this case that of the SLRO. Plaintiffs complain that Matthew was shunned, ostracized, and otherwise picked on by his fellow students, not because he was struck by Crouse, but because Crouse was later disciplined for striking him. In accordance with the test described above, this consists of demonstrating that: (1) there was no pedagogical justification for the use of force; (2) the force was excessive; (3) the primary motive for the use of force was harm, as opposed to a legitimate pedagogical objective; and (4) serious injury resulted. Therefore, he recommended enrolling her in a small, self-contained, special education program for the severely and profoundly retarded. Hankenson v. Board of Education, 15 Ill. App. Due to a change in state funding regulations, the CPS was able to provide Emily with one hour of home instruction per day. The CBE appeals the district court's order granting Thomas' motion for summary judgment and challenges the court's conclusion (1) that it developed an individualized educational program ("IEP") in violation of the Act's procedural safeguards, (2) that Ohio law reserves home instruction for those children who are unable to attend or to be transported to school, and (3) that school-based education is the only appropriate educational placement for Emily. Rowley, 458 U.S. at 189, 102 S.Ct.

569 (1936), saying that the contract there involved was entirely different, the teacher being merely a substitute, with no definite contract to teach at any time. Following the CCDD's evaluation, Mrs. Thomas met with the following personnel on September 19, 1984 in order to develop an IEP for Emily: Dr. Nancy Tolley, a psychologist representing the Cincinnati Public Schools ("CPS"), Dr. William Russ, Associate Director of Special Education for the CBE, Dr. Anna Byrne-Jandacek, a consultant in special education at the CCDD, and Bernadine Kessinger, Director of Services for Children at HCMBR/DD. 592, 597, 98 L.Ed.2d 686 (1988). 1979), a federal appeals court ruled that school authorities violated the First Amendment rights of free speech and press when they suspended several students for creating an underground student newspaper that was produced largely off-campus. Her application was approved by the board; the illness leave was granted on November 23, 1960. Long before Lewis, Judge Friendly, in Johnson v. Glick, 481 F.2d 1028 (2d Cir.1973), a prison abuse case, elaborated on this standard: The circuit courts have further elucidated this standard as it applies to corporal punishment in schools. . 2-201 et seq.). Plaintiffs' Brief in Opposition at 4.

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