Amanda Simmons Co-Authors COPAA Whitepaper on Representing Youth in Residential Treatment Centers
Amanda Simmons, founder of Ambika Law, PC, co-authored “IDEA, ADA and 504: Effective Representation of Youth in Residential Treatment Centers,” a whitepaper published by the Council of Parent Attorneys and Advocates (COPAA) and presented at the organization’s 2025 Annual Conference. She wrote the piece with fellow attorneys David German and Leigh Anne Hodges. Written for special-education practitioners, the whitepaper explains how the IDEA, the ADA, and Section 504 of the Rehabilitation Act can be used both to protect children within residential treatment centers and to keep them out of such placements in the first place.
COPAA is a national organization of attorneys, advocates, and parents dedicated to protecting the legal and civil rights of students with disabilities. Its annual conference and publications reach exactly the special-education bar this whitepaper is written to equip.
The whitepaper opens by defining the “troubled teen industry” — an imprecise umbrella covering bootcamps, wilderness programs, psychiatric inpatient facilities, therapeutic boarding schools, intermediate care facilities, and group homes — and documenting its scale: an estimated 120,000 to 200,000 children placed each year, supported by as much as $23 billion in taxpayer dollars flowing through Title IV-E, the IDEA, and Medicaid. It traces decades of documented harm, from 1974 Senate testimony likening one facility’s methods to coercive brainwashing, to the 2024 Senate Finance Committee’s conclusion that the risk of harm to children in these facilities is “endemic to the operating model.”
The authors ground the industry in the nation’s long history of institutionalization and the mid-century deinstitutionalization movement — from Brown v. Board of Education and President Kennedy’s 1963 call for community-based care, through the exposure of conditions at Willowbrook and the pivotal disability-rights decisions of the 1970s (PARC, Mills, Wyatt v. Stickney, and Goss v. Lopez). They then chart the industry’s modern growth: the shift from a private-pay to a public-pay business model, the influx of private-equity investment and corporate consolidation, and an operating model that rewards maximizing headcount while cutting staff and services. Against that backdrop, the whitepaper catalogs the documented abuses — sexual abuse (often beginning with invasive strip searches), medical neglect (including cases resulting in children’s deaths), the overuse of physical and chemical restraint and seclusion, educational abuse (from substandard instruction to fake diplomas), and sex and labor trafficking — noting that these risks fall hardest on BIPOC and LGBTQ youth and children with disabilities.
At its heart, though, the whitepaper is a practical guide for education lawyers. The authors map the federal oversight framework (the Departments of Health and Human Services, Justice, and Education) and the special-education tools that matter most — the IDEA’s guarantee of a free appropriate public education in the least restrictive environment, and the private-placement reimbursement principles of Town of Burlington v. Department of Education and Florence County School District Four v. Carter — while addressing the Supreme Court’s clarification of the IDEA’s administrative-exhaustion requirement in Perez v. Sturgis Public Schools (2023). They survey the growing wave of ADA “integration mandate” enforcement under Olmstead v. L.C., including the Department of Justice’s actions against Maine, Rhode Island, Georgia, and Alabama over the unnecessary segregation of children with disabilities.
The whitepaper closes with concrete advocacy strategies for preventing unnecessary placements: recognizing the potential conflict of interest that arises when a parent’s wishes diverge from a child’s educational needs and legal rights; assisting families with reintegration planning as children return home; addressing the disparate impact of residential placement on “crossover” youth involved in both the child-welfare and juvenile-justice systems; and advocating for community-based mental-health solutions — wrap-around services, in-home therapy, and robust IEP supports — that keep children with their families and in their communities whenever possible.
The whitepaper reflects Ambika Law’s trauma-informed mission and Amanda Simmons’s ongoing work to give special-education attorneys the legal tools to protect vulnerable children.
Read the full whitepaper: https://perma.cc/W2XQ-FXSM (Council of Parent Attorneys and Advocates, 2025).