A Missouri school district focused on special education restrains and secludes its students excessively and improperly, in “gross violation” of the Americans with Disabilities Act, a U.S. Department of Justice investigation has found.
The use of restraint and seclusion in schools operated by the Special School District of St. Louis County came in violation of district policy and state law, which allows for the practices only in the event of imminent danger of physical harm, the agency said in a letter to the district Monday. The district must “fundamentally change its practices” to avoid legal action, the letter says.
“During the investigative period, the district treated seclusion and restraint not as crisis responses to be used in rare emergencies but as a routine response to student behavior,” it says.
Schools operated by the Special School District of St. Louis County, which collectively enroll about 3,500 students with disabilities, secluded more than 300 students almost 4,000 times during the 2022-23 and 2023-24 school years, the Justice Department found. Schools restrained 150 students 777 times in that time period. One school with fewer than 100 students used seclusion 1,667 times, investigators found.
The district also partners with 22 traditional school districts to provide special education services, but the investigation focused on its own schools.
The findings come after years of debate over the controversial discipline practices, which are largely governed by state law.
The U.S. Department of Education defines restraint as the use of physical or mechanical restrictions that immobilize a student or reduce their movement. Seclusion occurs when a student is involuntarily confined to a room or area and physically prevented from leaving.
The agency has repeatedly advised schools to limit the practices, using them only as a last resort to prevent physical harm. Restraint and seclusion—practices that can be abused and misused—come with risks to students’ mental and physical health and educational development, and they are often ineffective at changing students’ behavior in the longer term, according to Education Department guidance.
Restraint, seclusion should not be routine practices, Justice Department says
The Justice Department opened the investigation into the Special School District of St. Louis County in May 2024, interviewing administrators and analyzing data, individualized education programs, and student-behavior plans. Investigators found the district-run schools use restraint and seclusion “in response to noncompliance with school rules, verbal conduct, and other behaviors that cannot lead to any safety threat.”
“For example, in one incident, a second-grade student was secluded for one and a half hours for knocking over her teacher’s coffee,” the investigation said. “In another, a seclusion was used because a second-grade student refused to go into music class. Another student was secluded for three and a half hours for drawing on her chair, cursing, and ‘being disrespectful.’”
Schools also routinely secluded students who were engaging in self-harm, putting them at further risk, investigators found.
“For example, in one incident, a fourth-grade student was secluded for two hours and 15 minutes, during which time he was ‘bitting [sic] his hands and wrists,’ '[s]aying that he wants to kill himself,’ and ‘banging [his] head on [his] knee,’” investigators found. “During another nearly two-hour-long seclusion, a fifth-grade student tied her shoelaces around her neck to the point that staff had to cut them off her neck.”
The Justice Department also identified 400 instances of supine restraints, during which a student is pinned face up on the ground, in the two-year period covered by the investigation. That position is more dangerous than other forms of restraint, investigators wrote.
A spokesperson for the district said officials reviewed the full report alongside lawyers Monday.
“Student safety and well-being continue to remain a top priority in SSD,” Superintendent Michael Maclin wrote in a letter to families about the investigation. “We take these concerns seriously and are committed to ensuring our practices support students’ safety, learning, and dignity.”
The district “serves students with significant and complex needs,” the letter says. “Our staff use a range of proactive behavior supports, de-escalation strategies, and individualized interventions to help support students.”
Calls for federal limits on restraint and seclusion
Violations of disability rights laws in schools, including the ADA and the Individuals with Disabilities Education Act, are investigated by the Education Department’s office for civil rights or by civil rights officials at the Justice Department.
It’s unusual for federal agencies to release findings and remedial measures before agreeing to a resolution plan with a district, said Denise Marshall, the CEO of the Council of Parent Attorneys and Advocates, which advocates for students with disabilities.
“Reading through the findings letter is very disturbing,” Marshall said. “And yet, the findings correlate to what we know is happening all across the country. I am thankful the department took such action.”
The agency released its findings because the district has failed to fully cooperate with its investigation, the DOJ letter says, detailing repeated delays, missed deadlines to produce data, and denied requests for investigators to visit schools while they are in operation. Because of those issues and concerns about proper documentation, it’s likely the investigation undercounted instances of restraint and seclusion, the letter says.
A district spokesperson did not respond to a question about allegations the district did not cooperate with federal officials.
Among the remedies the Justice Department requested from the district:
- Ending the use of seclusion and supine restraint;
- Prohibiting restraint except in cases of imminent threat of physical harm;
- Properly documenting restraints and notifying parents when they are used; and
- Providing affected students with “compensatory educational and counseling services to address physical and mental harm, trauma, and lost educational time.”
A bipartisan group of lawmakers from the House and Senate have repeatedly called for federal bans on seclusion and restrictions on the use of restraints through a bill called the Keeping All Students Safe Act, which was most recently reintroduced in December 2025.
The bill would draw a “bright line” about appropriate use of the measures, Marshall said. She called on more districts to make changes on their own.
“We know from research the first important step is the will to change,” Marshall said. “If that has to come from a DOJ investigation, so be it.”
