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When there is a lack of communication among special ists, as in Tony's case, mislabeling is bound to occur. Algozzine and Ysseldyke (1983) identify numerous cases of mislabeling. More specifically, they have found few psychometric differences between groups of students that have been labeled learning disabled and those students labeled low achievers. "Many of the learning disabled children did not meet federal definition guidelines as we operationalized them and many low-achieving children were 'learning disabled' by these same discussion rules" (p. 242).

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