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THE passage of the Rehabilitation Act in 1973 brought about a profound change in postsecondary education. With an ever-increasing number of students identified as having disabilities and requesting accommodations, service providers and students are gaining an awareness of legal rights as they pertain to academic accommodations. Section 504 of the Rehabilitation Act states the legal obligations of academic institutions receiving federal assistance: “No otherwise qualified person with a disability in the United States [. . .] shall, solely by reason of [. . .] disability, be denied the benefits of, be excluded from participation in, or be subjected to discrimination under any program or activity receiving federal financial assistance” (Amer. Council on Educ.).
Foreign language departments in colleges and universities are seeking appropriate avenues to accommodate students with language-based learning disabilities while also fulfilling the mission to teach foreign languages. Accommodation with a foreign language substitution course is a last resort and not automatic for students with language-based learning disabilities. It is only one of many options for individualizing an education plan to fulfill the foreign language requirement, yet because it is viewed as altering the academic standards of the university, it is the one that causes the most problems for university administrators.
Universities following the guidelines of the Rehabilitation Act already have in place educational accommodations for learning-disabled students. These may include oral testing, allowing a spell check or not counting misspelling, tape-recorded texts and lectures, extended testing time, and a grading emphasis that is adjusted to the student’s individual mode of communication.
Students with language-based learning disabilities are increasingly seeking foreign language course substitution accommodations, and foreign language departments are being asked to reexamine their departmental policies in seeking to accommodate these students. The first questions to be asked are, How is a language-based learning disability diagnosed? How does a language-based learning disability pertain to the learning of a foreign language? Then, What are the legal obligations of universities for accommodating students seeking foreign language substitutions? Finally, How are universities responding to the legal obligation of accommodating students with language-based learning disabilities while at the same time ensuring that they meet the degree requirement of a foreign language?
Even though eligibility criteria vary from state to state, the diagnosis of a learning disability has traditionally been documented by administering an individual intelligence test to establish cognitive status and potential for learning; administering an individual achievement test to measure skills in academic domains; applying state-specific criteria to document a significant discrepancy between IQ and one or more areas of achievement; and assembling evidence that other causes for poor achievement have been ruled out.
In general, a language-based learning disability is most evident in word attack and reading comprehension skills. Specific language impairment, as is evident in a learning-disabled reader, “interferes with the development of oral communication, with the comprehension of written language, and with the content of written expression” (Padget 168) not only in the native language of an individual but also in the foreign language that the student might be attempting to learn. A reading disorder interferes with understanding how spoken language is depicted by written language. Each phoneme in a spoken word is represented by a letter or letter combination. The inability to understand phonemes as units within spoken words is an essential difficulty for learning-disabled readers. Isolating and manipulating phonemes are not skills required for oral communication, but they are necessary for learning how to read and spell words. Phonological coding deficit can be detected in spoken language tasks that are designed to be phonologically complex (Padget). Therefore, both types of language-based learning disabilities, oral and written, are seen across the continuum from learning a native language (first language) to learning a foreign language (second language), with written language skills being the more deficient (Elbro, Borstrom, and Petersen). The research of Leonore Ganschow and Richard Sparks also found that those students with language-based learning disabilities in their first language displayed the same dysfunctions in learning a second language.
Intelligence tests help identify the presence of a language-based learning disability by determining the validity of a discrepancy between achievement level and intellectual capacity. The most widely used, individually administered IQ test is the Wechsler Intelligence Scale (WIS) for adults or children (Kamphaus). This measure of assessment has been useful in determining language-based learning disabilities because it indicates how a student performs on verbal tasks, on performance tasks, and on separate subtest tasks (Wechsler).
A language-based learning disability is categorized in the WIS by the presenting diagnostic features through the comparison of the individual achievement tests with the individual intelligence tests. These are labeled “Reading Disorder,” “Disorder of Written Expression,” “Expressive Language Disorder,” “Mixed Receptive-Expressive Language Disorder,” and “Phonological Disorder.” Groups of students with language-based learning disabilities tend to score higher on the performance scale than on the verbal scale of the WIS, and they tend to score lower on certain subtests (Searls). Specific intervention methodologies for instruction are listed in the recommendations section of “Psychological Evaluation,” of which these achievement and intelligence assessments are a part. The psychological evaluation is a portion of the required documentation for attaining support services. Disability support offices at universities review these assessments and recommendations for appropriate interventions and collaborate with students, faculty members, and staff in deciding on the accommodations needed to meet the academic requirements.
Verbal Scale Subtests
The “Information” subtest in the WIS measures long-term memory of general information gained from experience and education. Disabled readers consistently score lowest on this subtest (Kaufman). A low score on the information subtest could indicate a limited opportunity to increase the storage of general information because of an inability to read efficiently and an inability to store read information.
The “Similarities” subtest measures long-term memory, concept formation, ability to see associational relations, and logical and abstract thinking. It also measures the ability to select and verbalize relations between two concepts that seem dissimilar at first. An average or above average “Similarities” score combined with a low “Vocabulary” score implies that the reader has the ability for abstract thinking but that access to words for expressing this thinking has been restricted. Poor readers, however, do not score significantly low on this test because they can obtain facts and ideas necessary for concept formation in ways other than reading.
The “Arithmetic” subtest measures the ability to maintain and to focus concentration in order to extract the relations of numbers. In Jerome Sattler’s report, disabled readers ranked next to lowest on this subtest. This is because “Arithmetic” requires using the noncognitive functions of attention and concentration and combining them with the cognitive functions of manipulating abstract concept knowledge and numerical operations. “Information” and “Arithmetic” were the subtests most adversely affected by a weakened ability to enhance knowledge through reading.
The “Vocabulary” subtest measures learning ability, word knowledge acquired from experience, richness of ideas, kind and quality of language, and level of abstract thinking. In Sattler’s studies, disabled readers did better on this subtest than on “Information” and “Arithmetic.” This difference could be because today’s children have the opportunity to develop vocabulary from aural experiences like television, films, and computer programs.
The “Comprehension” subtest measures the ability to use practical knowledge and judgment in social situations and reflects knowledge of conventional standards of behavior. Poor readers are usually not penalized by this subtest, as the information needed is the type that can be acquired through practical experience and oral discussion.
The “Digit Span” subtest measures attention span, concentration, immediate auditory memory, and auditory sequencing. High scores may indicate good rote memory and immediate recall, with the ability to attend well in a testing situation. Low scores may indicate high anxiety in a testing situation, a hearing defect, disability in auditory sequencing, or high susceptibility to fatigue. It has been suggested that those with low “Digit Span” scores may have difficulty acquiring phonics skills that depend on memorization and sequencing of sound-symbol connections (Rugel).
Performance Subtests
“Picture Completion” measures alertness to the environment, visual memory, attention to detail, and visual perception. It also measures the ability to identify and isolate essential from nonessential characteristics. Alan Kaufman found “Picture Completion” to be the subtest on which groups of disabled readers most consistently made high scores. Kaufman relates that learning-disabled readers are successful on this subtest because the stimuli are concrete, as opposed to abstract; nonverbal (pictures rather than words); and visual.
“Coding” measures visual motor dexterity and the association of meaning with a symbol. It measures the ability to learn from visual and kinesthetic stimuli since the subject must write as well as visualize. Coding is difficult for learning-disabled readers because they must move their eyes quickly from the guide to the rows below, write, associate meaning with a symbol, and employ left-to-right progression. “Coding” was the fourth most difficult subtest for disabled readers (Searls).
“Picture Arrangement” measures cause-and-effect connections, visual sequencing, attention to details, visual perception, and concept formation. Poor readers are not penalized on this subtest because of the inherent meaningfulness of the stimuli and its nonverbal nature.
As the best single nonverbal measure of general intelligence, “Block Design” measures perception, analysis, synthesis, and reproduction of abstract designs, requiring that logic and reason be applied to spatial relations. As in “Picture Arrangement,” poor readers are not penalized by this subtest because it provides a good measure of reasoning for subjects who are unable to express themselves verbally.
“Object Assembly” measures part-to-whole relations, using visual anticipation, simple assembly skills, and visual-motor-spatial coordination. Learning-disabled readers who are oriented toward concrete thinking are successful on this test.
“Symbol Search” measures speed of visual search, speed of mental processing, visual short-term memory, spatial visualization, and visual-motor coordination. Low scores may indicate inadequate visual acuity, visual perception problems, anxiety, or distractibility.
Achievement tests measure an individual’s skills in specific subject areas. Practitioners and educators accept most widely the battery of achievement tests known as Woodcock-Johnson-Revised (WJ-R) (Taylor). In relation to diagnosing reading- and language-based learning disabilities, the cognitive battery is used to access scholastic aptitude. According to its authors, the WJ-R can be used for diagnosing or identifying weaknesses and determining psychoeducational discrepancies (Woodcock and Johnson). There are seven broad cognitive factors included in the WJ-R and all seven have a direct influence on reading: long-term retrieval, short-term memory, processing speed, auditory processing, visual processing, comprehension-knowledge, and fluid reasoning. In addition, there are seven subtests used selectively to probe specific cognitive areas: visual-auditory learning, memory for words, cross out, sound blending, picture recognition, oral vocabulary, and concept formation.
Individual intelligence and achievement tests provide comprehensive and sensitive measures, which, viewed as a pattern, can be analyzed to present an accurate picture of the individual’s academic potential, strengths, and weaknesses. Pattern analysis is used as an aid in diagnosing learning disabilities. It is a procedure in which scores on different subscales of intelligence and achievement are interpreted by discrepancies between ability (intelligence) and performance (achievement).
Because a language-based learning disability is specific rather than pervasive and primarily interferes with academic progress, postsecondary educators who are grappling with the issue of accommodating students with learning disabilities can take the theoretical framework of a learning-disability diagnosis and break it down into appropriate individualized instructional procedures for intervention. Individualized intervention is exactly that—individual. With each student’s complete psychological evaluation, recommendations are included by the diagnostic practitioner for specific areas of the disability. When students have taken the foreign language class and have used the appropriate study skill and classroom accommodations but still cannot reach an appropriate proficiency level in the second language, a foreign language substitution could be considered as a viable intervention to complete the university’s required foreign language component. The cultural dimension of a language course presents the opportunity for constructing a course substitution. A course substitution for foreign languages meets the criteria of education in culture without requiring acquisition of speaking and writing and yet offers exposure to another language. Each student with a reading learning disability seeking the accommodation of a foreign language course substitution can expect a specific individualized education plan that simultaneously meets degree requirements and accommodates specific disability needs.
In the mid-1990s, Boston University found itself in a bitter struggle as it dealt with a myriad of disability issues. What was the controversy really about? Was it that a stubborn academic institution did not want to adhere to its mandated obligations under the law, or was the institution waging a legitimate battle that it saw as necessary to protect the integrity of its academic program and services?
Ten students sued Boston University, stating that the new policies instituted by the administration violated the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act. The suit was a protest of two new policies:
(1) Students seeking accommodations for learning disabilities were required to submit a diagnostic evaluation no more than three years old
(2) Students no longer were exempted from certain course requirements, such as the foreign language requirement in the liberal arts curriculum; students might still qualify for accommodations, but they were required to take the courses (“Boston University Lawsuit”)
The suit also claimed that the ADA prohibits across-the-board rulings on course waivers without taking into account individual needs. All the questions were not answered, but the Boston University litigation served to clarify the issue of whether postsecondary institutions can refuse to allow foreign language course exemptions or substitutions for students with learning disabilities. “Particularly with respect to the issue of course substitution, this class action concerns the interplay between the rights of learning-disabled students to reasonable accommodations and the rights of institutions of higher education to establish and enforce academic standards” (Guckenberger v. Boston U).
Blanket refusals to provide accommodations to a class of individuals with disabilities are suspect under the law. The regulations implementing section 504 list course substitutions as appropriate academic adjustments. “Modifications may include [. . .] substitution of specific courses required for the completion of degree requirements [. . .]” (Heyward). Therefore, it is questionable whether an institution can choose to refuse to consider and provide a type of accommodation that is specifically identified in the regulations.
However, there is support under the law for having students with disabilities meet legitimate degree requirements. The university must first be able to establish that the requirement in question is essential to a particular program of study (Wynne v. Tufts). Foreign language departments have conducted research on why students should learn a second language and how this aspect of a degree plan is essential to postsecondary education (Marshall). Implementation of a foreign language program therefore stems from the theoretical stance that study of a foreign language should be part of a degree plan.
The essential requirement criteria for a foreign language in a degree plan should be a written policy supported by appropriate academic experts in the form of a researched study. The views of individuals who are not knowledgeable in the field of learning disabilities are not sufficient to support the denial of services. Unless it seeks the opinion of experts, a university will leave itself open to the charge that the decision is arbitrary and capricious and the reasons given to support it are a pretext for discrimination (Simon 1–2). These were the arguments leveled against the provost at Boston University who took it on himself to review the documentation of the students with disabilities seeking accommodations.
In addition, blanket policies refusing to allow the accommodation of course substitutions, like the one at Boston University, preclude the institution from conducting the individualized inquiry that the Supreme Court ruled is necessary to determine whether a person with a disability is qualified as learning disabled. Individualized inquiry requires that an institution assess the skills and abilities of each student having a disability in conjunction with academic program criteria. An institution has a “real obligation to seek suitable means of reasonably accommodating a student and to submit a factual record indicating that it conscientiously carried out this statutory obligation” (Wynne v. Tufts). A policy dictating that course substitutions for foreign languages will not be considered for students with disabilities does not permit the institution to meet this obligation for each individual student.
When an institution determines that a requested accommodation would fundamentally alter the educational program, as it might in the case of a foreign language course substitution, a documented analytic approach must be followed (Easley v. Snider). In order for this documented analytic approach to take place, a university must proceed with caution and implement the following proceedings to comply with section 504 of the ADA and with recent litigation rulings dealing with the issue of foreign language course substitutions: first, the university must have a written statement of why the foreign language is an essential part of the program; second, students must have current and appropriate documentation for language-based learning disabilities; third, students must be active participants with the disability support office and academic advisers in charting and implementing applicable accommodations; and fourth, foreign language course substitution must be seen as an intervention of last resort, so that it does not interfere with any student who wants to learn a foreign language.
The Disability Support Office at Baylor University went back to the drawing board with cooperation from the administrators and modern foreign language department to establish a policy and procedure for foreign language substitutions that would meet both the needs of the students with disabilities and the requirements of Baylor University. To get a sense of how others respond to the question of substitution, I created a questionnaire that was sent to national four-year institutions that are members of the Association on Higher Education and Disability (AHEAD) and that have disability support offices operating on their campuses. The questionnaire asked for information concerning policy and procedure for implementing foreign language substitutions.
The Office of Access and Learning Accommodation, the support office for students with disabilities at Baylor University, sent the questionnaire out by e-mail. The questions were:
Of the 443 surveys that were sent, forty-one were returned either because of incorrect addresses or because the recipient no longer worked in a relevant capacity. Seventy-four schools responded with a varying degree of detail. All seventy-four respondents said they required updated documentation of a diagnosed language-based learning disability from a licensed psychologist or psychiatrist. Fourteen schools have no requirements for foreign language and twelve do not have a policy for foreign language substitutions but are investigating possible procedures. Two of the schools required that a psychologist in their own counseling office review the documentation, eleven required a review by the university’s disability specialist in the disability support office, nine required review by an administrator or dean, and four required a review by a foreign language committee. Four schools do not have a disability support office so a standards or executive academic committee gives approval for course substitutions. Eleven schools require that a previous history of failed attempts at learning a foreign language be submitted before substitutions would be considered. Nineteen universities ask for letters of support from the disability specialist on campus with letters requesting the accommodation of a foreign language substitution by the student.
Once the foreign language substitution request is granted, courses for the substitution may involve history, language, culture, art, linguistics, or communications. A sampling of courses approved for foreign language substitutions from the surveyed universities are Transnational Chinese Cinema, Postwar Japan, Italian Literature in Translation, Russian Literature in Translation, Japanese Culture, European history, International Studies, geography, Continental Studies, Existential Philosophers, Age of Revolutions, Religions of the World, East and West Philosophy, social and behavior sciences, Human Communications, anthropology, English Words from Classical Elements, linguistics, classics, international political science, and American Sign Language.
As a result of my survey and the urgent need of accommodating students with language-based learning disabilities with a foreign language substitution, the Foreign Language Committee at Baylor University refashioned its mission statement and then worked with the director of the Office of Access and Learning Accommodation to solidify a working foreign language substitution policy and procedure. The study of world languages has long constituted an integral part of Baylor University’s educational programs, but a formal mission statement was required to explicitly establish the rationale for world language study. The Department of Modern Foreign Languages’s mission statement now reads:
Baylor’s sphere of influence is indeed the world. Within the context of an ethnically and culturally diverse community, Baylor strives to develop [. . .] educated leaders [. . .] and skilled professionals who are sensitive to the needs of a pluralistic society. Within the undergraduate program, the University seeks to familiarize students with the principal bodies of knowledge, cultural viewpoints, belief systems, and aesthetic perspectives that affect the world in which they live. Baylor encourages all of its students to cultivate their capacity to think critically. The world language classroom, from its unique position of exploring cultural perspectives from within the target language, addresses all these goals.Baylor University desires to educate men and women for worldwide leadership. As a nation, we can maintain our international influence and prestige only by preparing individuals to appreciate and deal with the diversity that exists both outside and inside our borders. The world language classroom creates an intermediary space between the native and the target language/culture in which students must adapt to an unfamiliar environment. Only by experiencing another language from within, not through translation, can students recognize the extent to which linguistic expressions and structures shape reality. Study of a world language broadens their cultural perspectives, prepares them for life-long learning, and enhances their travel and study abroad experiences in ways unavailable to the monolingual.
Baylor University seeks to prepare professionals who are sensitive to the needs of a pluralistic society. Cross-cultural vision benefits both the local and global communities. The twenty-first century needs leaders at all levels who can function successfully in diverse settings. University graduates with world language training are uniquely prepared to assume such leadership roles in a pluralistic society. Students with world language skills have an unlimited range of future career possibilities in education, business, government, including the diplomatic corps and security, journalism, the health, social and legal services, transportation, computer and technological development, telecommunications, the transportation industry, religious and denominational service, and many other professions closed to the monolingual. Statistics show that they receive higher salaries throughout their professional lifetime. Employers aggressively seek graduates with world language skills.
Baylor University wishes all graduates to be familiar with the principal bodies of knowledge, cultural viewpoints, belief systems, and aesthetic perspectives that affect the world in which they live. Today’s foreign language class challenges students to discover their own limitations, deal with ambiguity and conflicting perspectives, and acknowledge the values and beliefs of others. World language study furthers interdisciplinary learning by integrating language, anthropology, art, history, literature, music, philosophy, religion, science, and sociology, and it does so with more immediacy and depth of understanding. Moreover, interdisciplinary knowledge gained through the language contributes to a lifelong learning process.
The capacity to think critically is one of several personal strengths developed through language study. In addition to the evident cultural and linguistic benefits derived from the study of a world language, reports point to a number of ancillary results such as: 1) increased interpretive skills and enhanced critical thinking, 2) self-restraint and academic discipline,
3) appreciation for working toward long-term goals, and 4) the self-satisfaction experienced by those who learn another language, use it to reach out to another person in that language, and find that “it works.”The study of world languages offers students numerous benefits and skills. To realize these most effectively, students should consider carefully the options consistent with their personal and career needs. Students are encouraged to seek individualized guidance from the Department of Modern Foreign Languages or the Department of Classics in order to develop a personalized program. Only with a quality foreign language experience can an individual claim to be truly well educated.
We established a procedure to serve the foreign language needs related to degree and career choices of students with language-based learning disabilities seeking a foreign language course substitution. With the team effort of the dean of arts and sciences, the director of the Office of Access and Learning Accommodation, and the Modern Foreign Language Committee, an individual education plan will be developed for each student seeking a foreign language substitution. The following form, to be signed by the dean of arts and sciences and the director of the Office of Access and Learning Accommodation, streamlines the process.
The Baylor University Office of Access and Learning Accommodation (OALA) Request for Foreign Language Course SubstitutionI, ________________ (SSN# ________________), have authorized the Office of Access and Learning Accommodation to verify my eligibility for a foreign language course substitution.
I. I have followed the Policy and Procedure for classroom accommodation through OALA.
II. OALA has provided the Foreign Language Committee with a letter verifying current documentation of a diagnosed disability.
III. A course substitution petition has been filed with the Dean’s office of Arts and Sciences.
IV. I have met with the Foreign Language Committee to coordinate an individual Education Plan to fulfill the foreign language requirement.
The first requirement on the checklist of the request for foreign language course substitution is verification that the student is in full accord with the university’s disability support office. This includes providing the office with current and correct documentation verifying the disability, use of the study skills and counseling support provided by the office, and use of the appropriate classroom accommodations as implemented with the foreign language instructor. The second requirement on the checklist is that the student has provided the foreign language committee with a letter of support from the disability office stating that a course substitution is an appropriate accommodation for this individual. The third item requires the student to fill out and file a petition with his or her respective school requesting the need for the substitution. The final requirement is that the student meet with the foreign language committee to discuss and decide the particular courses that would be considered appropriate for the student’s specific degree plan and postgraduation aspirations.
It is clear that there is some confusion and legitimate questions exist regarding the proper accommodation of students with learning disabilities (Daniel). Many schools, as indicated in this study, have responded to the dilemma of foreign language substitutions. The Boston University case has shone a spotlight on the confusion and questions concerning the merit of offering foreign language course substitutions as an accommodation for a learning disability. The reputations and academic integrity of universities are at stake.
The challenge for the postsecondary institution is whether it can establish that its past practices with respect to students with learning disabilities were academically acceptable and not initiated merely to satisfy federal statutes and regulations (Daniel). As a result of the Boston University case, it is necessary for the university to present something more than the philosophical opinion of an administrator that foreign language course substitutions were not acceptable. Instead, a university must use individualized inquiry to determine appropriate accommodations, establish a policy in regard to the course in question that shows it is essential to a specific degree plan and that it consciously carries out its obligation to consider alternative accommodations. In the light of the results of litigation, Baylor University concluded that a foreign language course substitution can in some cases be considered an appropriate accommodation for a student with learning disabilities. Several options are available to fulfill the accommodation request for a foreign language substitution.
“Boston University Lawsuit Could Have Incredible Impact on Disability Services.” Disability Compliance for Higher Education 2.1 (1996): 1, 8.
Daniel, Wallace. Personal interview with the dean of arts and sciences, Baylor University, regarding the foreign language substitution policy. Aug. 1997.
Easley v. Snider. 841 F. Supp. 668 (ED. Pa. 1993).
Elbro, C., I. Borstrom, and D. K. Petersen. “Predicting Dyslexia from Kindergarten: The Importance of Distinctness of Phonological Representations of Lexical Items.” Reading Research Quarterly 33.1 (1998): 36–60.
Ganschow, Leonore, and Richard L. Sparks. “Foreign Language Learning Disabilities: Issues, Research, and Teaching Implications.” Success for College Students with Learning Disabilities. Ed. Susan A. Vogel and Pamela B. Adelman. New York: Springer, 1993. 283–322.
Guckenberger v. Boston University. 957 F. Supp. 306 (D. Mass. 1997).
Heyward, S. Workshop conducted at St. Phillips College by Disability Access Institute. San Antonio. 1997.
Kamphaus, Randy W. Clinical Assessment of Children’s Intelligence. Boston: Allyn, 1993.
Kaufman, Alan S. Intelligent Testing with the WISC-III. New York: Wiley, 1994.
Marshall, D. G. “At Home on Babel Tower: Why Should Children Learn a Second Language?” ADFL Bulletin 21.2 (1990): 5–11. [Show Article]
Mission Statement. Dept. of Modern Foreign Langs., Baylor U. Dec. 1998.
Padget, Y. S. “Lessons from Research on Dyslexia: Implications for a Classification System for Learning Disabilities.” Learning Disability Quarterly 21 (1998): 167–77.
Rugel, R. P. “WISC Subtest Scores of Disabled Readers: A Review with Respect to Bannatyne’s Recategorization.” Journal of Learning Disabilities 7 (1974): 48–55.
Sattler, Jerome M. Assessment of Children. 3rd ed. San Diego: Sattler, 1998.
Searls, Evelyn F. How to Detect Reading/Learning Disabilities Using the WISC III. Newark: Intl. Reading Assn., 1997.
Simon, J. “Guckenberger v. Boston University . . . A Long Awaited Decision.” Alert 21.5 (1997): 1–4.
Taylor, Ronald L. Assessment of Exceptional Students. Boston: Allyn, 1993.
Wechsler, David. Wechsler Adult Intelligence Scale. San Antonio: Psychological Corp.; New York: Harcourt, 1997.
Woodcock, Richard W., and M. B. Johnson. Woodcock-Johnson Psycho-Educational Battery. Rev. ed. Allen: DLM, 1989.
Wynne v. Tufts University School of Medicine. 976 F. 2d 791 (1st Cir. 1992).
© 2002 by the Association of Departments of Foreign Languages. All Rights Reserved.
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