Myths Behind Restraint and Seclusion – A Literature Review

Today’s guest author is Jane Hodell.

Jane is a dual degree student at Saint Louis University (St. Louis, Missouri) in Law and Public Health who chose to explore seclusion and restraint for her capstone project and a seminar paper for her disability justice class.

The Problem of Interest

Federal data indicates that in the United States, upwards of 100,000 students are restrained and secluded (R&S) every year in public schools (Kim, 2022). The OCR defines restraint as the act of “restricting the student’s ability to move his or her torso, arms, legs or head freely” (Office of Civil Rights, 2016), which includes restriction as physical, a personal restriction to immobilizes, mechanical, or through equipment or a device. The OCR defines seclusion as “confining a student in a room or area that he or she is not permitted to leave” (Office of Civil Rights, 2016).  

In medical settings and schools, R&S is intended to only be used in situations that pose “imminent danger of serious physical harm to the individual or others” (U.S. Department of Education, 2021). The stated purpose of R&S in education is for crisis management and is supposed to be the safest practice to manage and de-escalate disruptive, harmful behavior. (U.S. Department of Education, 2021). The intended use of R&S in schools stems from the current use of R&S in medical settings with potentially violent residents (Huckshorn et al., 2023). However, research from the behavioral health field indicates R&S is not safe and may have harmful physical and psychological effects on the individual subjected to R&S and the provider (Day, 2022). Additionally, research points to R&S having the opposite effect of de-escalation and rather leads to superficial compliance and increased misbehavior in the short and long term resulting in more instances of R&S for the child (Day, 2022). Children have been physically injured, psychologically traumatized, and died due to the use of R&S in schools (Day, 2022). Furthermore, cases of improper use of R&S that have led to psychological trauma, injury, and death, are not one-offs. One State’s data indicates students were injured at least 1,062 times in the 2019-2020 academic year. This statistic is likely low due to poor reporting (Munson et al., 2022). R&S practices are also found to be disproportionately used on children with disabilities, elementary school children, boys, and black and Hispanic students (Katsiyannis et al., 2020). Data largely suggests that four out of five students who experience R&S are children with disabilities (Kim, 2022). 

The federal government recognized the harmful impact that R&S has. Federal laws have been implemented regulating when and how R&S can and should be used in medical settings and facilities (42 CFR § 483.358). The federal government also acknowledged the harmful physical and long-term psychological impact of R&S on children when used in school. Surprisingly, there is no federal law to protect children while at school from being subjected to these practices (Nunno, 2012).

This review of the literature will analyze how the use of R&S has a traumatic impact on children, is not a safe way to address behavioral issues, and only increases the use of R&S, pointing to the need to implement different practices to manage behavioral issues to reduce rates of R&S to only the intended use. I will also propose solutions and recommendations to address how the United States can keep all children safe in school from R&S. 

The audience target audience that I will be addressing includes the federal government, the Department of Education (DOE), and parents. The federal government is a key stakeholder because they are the legislative body that would create and amend federal laws to protect all children from R&S.  The DOE is a key stakeholder because they are the agency that should enforce and regulate the use and misuse of R&S. Lastly, parents are key stakeholders because they are the individuals that will be advocating and litigating for their children who are subjected to R&S. 


To gather data examining the traumatic impact of R&S on children, I started by conducting a general Google search using search terms such as “restraint and seclusion in schools,” “what is restraint and seclusion in schools,” and “laws behind restraint and seclusion in schools.” This Google search provided me with articles highlighting the misuse and abuse of R&S in schools across the country. Articles from CT Insider, NPR, and government websites discussed how lawmakers have acknowledged the physical and psychological impacts of R&S but that cases across the country are still rising. These articles were helpful in hearing personal stories of trauma that children incurred because of R&S practices in schools. 

To explore the relationship between trauma and R&S, I then looked specifically at PubMed and Google Scholar to find peer-reviewed research articles related to the topic. Search terms used were “trauma of restraint and seclusion in schools,” “impact of restraint and seclusion on children psychologically,” “trauma behind restraint and seclusion,” “harm behind restraint and seclusion,” “brain science,” “restraint and seclusion,” and “psychological impact.” This search provided me with research discussing systematic reviews discussing interventions and trauma, therapeutic utility, and critical examinations of R&S. 

Lastly, I researched specific court cases. I used search terms such as “notable court cases restraint and seclusion” and “current court cases restraint and seclusion” in order to try and locate specific cases. This led me to three notable cases, Kerri K et al. v. State of California et al., Q.T. et al. v. Fairfax County School Board, et al., and Maryland school district. These cases provided insight into how the plaintiffs argued that R&S is a violation of law, is traumatizing, dangerous, and remedies. 

Based on the general research conducted on this topic and discussions with organizations such as the Alliance Against Seclusion and Restraint, I conducted more “general” Google searches because the data is limited on how R&S in schools impacts children. Some limitations of this method include potential bias, missing viewpoints, and areas of discussion. However, I reached a point of saturation while conducting my research and the literature I was finding. Therefore, I didn’t narrow my searches to a specific time period. Most data and articles that discuss R&S are from 2009 – 2023. This is because federal conversation surrounding R&S in schools began in January 2009 when the National Disability Rights Network revealed the misuse of R&S in schools across the country, documenting the injuries, trauma, and deaths sustained as a result of the misuse in a report called School is Not Supposed to Hurt (National Disability Rights Network, 2010). 

Review of the Literature

History of Restraint and Seclusion in Schools 

Schools’ use of R&S began in the 1950s when the United States shifted towards more inclusive practices in education, healthcare, and other sectors. Prior to the 1950s, adults and children with disabilities were housed in restrictive institutions and denied access to public education. However, after the 1954 holding in Brown v. Board of Education which held that segregation in schools was unconstitutional, disability rights advocates began to fight for the disabled community and the abuse suffered by adults and children living in restrictive institutions (Kim, 2022). 

In 1975, the Education for All Handicapped Children Act was passed, later known as the Individuals with Disabilities Education Act (IDEA), requiring children with special needs to be integrated into schools. This act was a milestone for disability rights. While laws can make positive changes, they also carry unforeseen consequences. Schools were now serving children with disabilities with little knowledge of what to do. School settings emphasize order, compliance, and corporal punishment which resulted in schools adopting R&S practices intended for medical and psychiatric settings (Kim, 2022).

Harmful Effects of Restraint and Seclusion 

R&S is intended to limit injury and danger to the student and teacher. However, data indicates the opposite. Studies indicate R&S puts teachers at harm more than students (Munson, 2022). Teachers who have had to restrain or seclude children report the experience as physically and mentally painful. Teachers have been punched in the face and hit in the head with chairs by using R&S (Lombardo et al., 2019). Teachers reported locking themselves in a bathroom and crying after having to perform R&S. Many don’t feel physically prepared or mentally prepared to perform R&S, which leads to a higher risk of injury (Lombardo et al., 2019).

 Students experience an array of negative consequences because of R&S. Parents report that their children subjected to R&S experience psychological trauma, receive post-traumatic stress disorder diagnoses, and have been physically injured (Abamu, 2019). Children subjected to seclusion have banged their heads against a wall, suffered nosebleeds, broken bones, and defecated themselves, all because of R&S (Abamu, 2019. In too many cases, children have died (Kim, 2022). Furthermore, the tactics used produce anxiety, fear, and decreased ability to learn. One report indicated that all children experience trauma from restraint and seclusion (Association of University Centers on Disability). These traumatizing experiences impact a child’s brain development and behavior and can also re-traumatize students (Marshall, 2015) and worsen problematic behavior (Laku et al., 2020). An article described one man who is retraumatized in life when he encounters certain things and now, as an adult, acts out more aggressively and is afraid he could be arrested due to this behavior which all stemmed from R&S being used on him in elementary school. Another student subjected to R&S can no longer use the bathroom with the door closed and is afraid to be in the dark. These practices traumatize children at the moment and lead to long-lasting effects post-school years (Munson et al., 2022). 

Three notable legal cases, all resulting in settlements, have been brought against school districts resulting from improper use of R&S tactics and highlight the physical and psychological impacts on the students  Kerri K et al. v. State of California, et al.Q.T., et al. v. Fairfax County School Board, e. al., and, most recently, the U.S. Department of Justice (DOJ) settling with Maryland School District. Recent investigations by the DOJ into Cedar Rapids Community School District in 2022 and Anchorage School District in 2023 have also led to settlement agreements. Strong settlement arrangements finding fault with the districts have required them to eliminate seclusion, reduce restraint, and document, which are considered big wins in terms of settlements (United States Department of Justice).

Kerri K et al. v. State of California, et al., filed in 2019, is the first notable and landmark case. The class action was brought by four students who currently go or went to Floyd I. Marchus School (Marchus) in California and was brought against the state of California, Contra Costa County Office of Education, and individuals who worked at the Marchus school. The petition claimed their children were subjected to physical and emotional harm due to misuse of R&S. Allegations include one child “cowering in a corner, was picked up and thrown against a wall, her legs pulled apart and her head bent toward the floor” all for throwing a water bottle towards a staff member. Another allegation discussed the misuse of restraint by five adults who increased pressure and ignored the child pleading that she was being hurt even once a staff member determined the restraint was problematic (Kerri K et al. v. State of California, et al.). 

Q.T. et al. v. Fairfax County School Board et al. is the second notable lawsuit brought by parents and disability rights activists in 2019 against the Fairfax County School Board. The petition alleged the school used “excessive and unjustified discrimination, psychological trauma, and physical harm inflicted by their illicit use of restraints and seclusion to silence, detain, segregate, and punish students with disabilities.” The use of R&S was compared to “techniques more in tune with incarcerated prisoners than students with disabilities.” Allegations included children secluded for two months consecutively until “deemed to be good behavior for three consecutive days,” students defecating themselves to end seclusion resulting in teachers making them clean up their own urine, and seclusion being a punishment for not completing a math worksheet. These children reported psychological trauma, increased anxiety, and physical injuries because of these restraint and seclusion tactics (Q.T. et al. v. Fairfax County School Board, et al.)

Maryland School District is the most recent notable case brought by the DOJ in 2020 against the Maryland School District. DOJ found unnecessary and repeated use of R&S inflicted on students as young as five for non-emergency reasons leading to distress, trauma, and instances of self-harm (United States Department of Justice).

Brain research, personal stories, and court cases have all documented the traumatic physical and psychological harm that R&S can have on students. This trauma impacts them as children and follows them into adulthood. Considering there is new research and literature that points toward better, less traumatizing practices to manage students with behavioral issues, R&S should only be used for the intended purpose, to prevent imminent danger of serious physical harm to the individual or others, which should be expressly defined by Congress. However, R&S still seems to be the most utilized behavioral intervention.

Alternatives to Restraint and Seclusion 

Alternatives to R&S in schools exist that don’t have to be physically and psychologically traumatizing. The research behind behavioral interventions has changed. Positive behavior interventions and supports, de-escalation techniques, and positive reinforcement techniques are all proven methods in the reduction of incidents with children exhibiting behavioral problems (Association of University Centers on Disability). An evidence-based and data-driven framework was used in around 20% of schools in the United States and proved to reduce disciplinary incidents and promote greater productivity, safety, and learning. This technique moves away from the R&S method of discipline to manage behavior and turns toward preventative measures, positive academic learning environments, the needs of the student, and tools for teachers to identify and mitigate challenging behaviors (Harkin, 2014). 


On a policy level, I suggest that in order to make school safe for all children, the federal government not only needs to strengthen protection under disability rights laws by amending the ADA to address R&S in schools specifically but also needs to think more broadly for all students by creating a federal law protecting all children from restraint and seclusion in schools, not just the disabled. Additionally, there are enormous monetary costs associated with R&S practices (Kern, 2020). Schools need liability insurance, crisis prevention training, and money to fix property damage to school facilities resulting from R&S incidents (Kern, 2020). Children and staff routinely become injured from performing R&S leading to medical costs (Kern, 2020).  Schools also face lawsuits from R&S misuse and other legal liabilities (Kern, 2020). Therefore, I propose that by eliminating R&S to only cases of serious physical injury, “educational settings can provide better quality education with increased staff satisfaction and decreased staff turnover, resulting in significant cost savings and a safer environment (Kern, 2020)..” 

On an institutional level, it is also important to recognize the challenges that schools face regarding decreased fiscal resources, reduced capacity to fund specialized services, teacher shortages, and a lack of trained teachers to work with children with behavioral issues and disabilities (Nunno, 2012). It is easy to place blame on teachers. However, they are doing the best they can with the resources and training provided by schools with regard to proper R&S practices. The problem is schools are not equipped to handle the number of children in schools who have disabilities resulting in R&S practices being the “easier” resort to handle incidences rather than other behavioral management strategies (Nunnno, 2012). The system is strained. Therefore, I suggest that although a law specifically addressing R&S is important, it is also necessary to relieve stressors in the educational system. Teachers need to be properly trained in how to handle students with behavioral issues and need to be given and provided with the proper tools and resources to foster a safe learning environment for children as well as themselves. 


Based on the literature, the use of R&S to handle behavioral issues in children at school has far-reaching implications outside of just the classroom. R&S practices disproportionately impact children based on disability, race, sex, and age. R&S practices result in physical injury or death to children and faculty. These practices psychologically traumatize children setting them up to be fearful in the real world. The behavioral health field has stated that there is a lack of evidence that R&S is safe or therapeutic and has put forward evidence that positive behavioral interventions mitigate challenging behaviors while fostering a safer and more productive learning environment. Ideally, these positive behavioral interventions will be phased in by all states resulting in R&S practices no longer needing to be used except in cases of “imminent danger of serious physical harm to the individual or others” (U.S Department of Education, 2021).


SourceSearch Terms Summary of Article
Association of University Centers on Disability Trauma of restraint and seclusion in schoolsDebunking the Myths of Restraint and Seclusion
United States Senate Dangerous use of seclusion and restraints in schools remains widespread and difficult to remedy: a review of ten casesChildren harmed by restraint and seclusion 
Council of Parent Attorneys and Advocates trauma behind restraint and seclusionTrauma-Informed Care: Child Safety
National Disability Rights Network harm behind restraint and seclusionSchool is Not Supposed to Hurt
Council of Parent Attorneys and AdvocatesThe Effects of Restraint and Seclusion on Patients with Mental Disorder: A Systematic ReviewTrauma-Informed Care: Child Safety Without Seclusion and Restraint
American University Radio Restraint and seclusion in schools harmful Children Are Routinely Isolated In Some Fairfax County Schools. The District Didn’t Report It.
CT InsiderRestraint and seclusion in schools harmfulControversial and often used, these little-known practices cause harm, even death, among U.S. schoolchildren.
Kappan History of restraint and seclusion in schools The restraint and seclusion of students with disabilities.
Department of Education Restraint and seclusion in schools Dear Colleague Letter
United States Department of Health and Human Services Restraint and seclusion in schoolsPromoting Alternatives the use of Restraint and Seclusion
United States Department of EducationRestraint and seclusion in schoolsRestraint and Seclusion: Resource Document
NPR Restraint and seclusion teachers A Dreaded Part of Teachers’ Jobs: Restraining and Secluding Students
SourceSearch Terms Summary of Article
Sage JournalsRestraint and seclusion Preventing Restraint and Seclusion: A Multilevel Grounded Theory Analysis
Google Scholar Psychological trauma restraint and seclusion Subjective distress after seclusion or mechanical restraint: one year follow up of a randomized controlled study
Google Scholar Brain science restraint and seclusion Trauma-informed Interventions to Reduce Seclusion, Restraint, and Restrictive Practices Amongst Staff Caring for Children and Adolescents with Challenging Behaviors: A Systematic Review
Google Scholar GAO report restraint and seclusionGAO Report
PubMedImpact of restraint and seclusion in schoolsExamining the therapeutic utility of restraints and seclusion with children and youth: the role of theory and research in practice
PubMedPsychological impact of restraint and seclusion Restraint and seclusion: the perspective of services users and staff members
PubMedPsychological impact of restraint and seclusionThe mentally ill and social exclusion: a critical examination of the use of seclusion from the patient’s perspective
SpringerLinkPsychological impact of restraint and seclusionQ.T. et al. v. Fairfax County School Board et al.
Journal of Psychiatric and Mental Health Nursing harm behind restraint and seclusionSafety hazards in patient seclusion events in psychiatric care: A video observation study  
Advances in Neurodevelopmental Disorders harm behind restraint and seclusionExploring the disproportionate use of restraint and seclusion among students with disabilities, boys, and students of color.
American Journal of OrthopsychiatryRestraint and seclusion harmful schools Restraint and Seclusion Use in U.S. School Settings: Recommendations From Allied Treatment Disciplines
SpringerLinkRestraint and seclusion is not therapeutic Restraint and Seclusion
Sage Journals Restraint and seclusion CCBD’s Position Summary on the Use of Physical Restraint Procedures in Educational Settings.
SourceSearch Terms Summary of Article
Disability Rights Education and Defense Fund Kerri K et al. v. State of California, et al.Kerri K et al. v. State of California, et al.
WestlawQ.T., et al v. Fairfax County School Board, et al.Q.T., et al. v. Fairfax County School Board et al.
The United States Department of Justice Maryland school district seclusion and restraint caseThe United States Department of Justice. Justice Department Reaches Settlement with Maryland School District to Protect Students with Disabilities (2021).
The United States Department of JusticeRestraint and seclusion in schools court cases Seclusion Enforcement – Recent Investigations


Abamu, J. (2018, August 20). Children are routinely isolated in some Fairfax county schools. The district didn’t report it.WAMU. Retrieved April 10, 2023, from 

Day, D (2022). Examining the Therapeutic Utility of Restraints and Seclusion With Children and Youth: The Role of Theory and Research in Practice. American Journal of Orthopsychiatry, 72: 266-278.

Harkin, T. (2014, February 12). Dangerous use of seclusion and restraints in schools remains widespread … United States Senate. Retrieved April 23, 2023, from 

Huckshorn, K. A., LeBel, J., Duxbury, J., & Hamilton, B. (1970, January 1). Restraint and seclusion. SpringerLink. Retrieved April 23, 2023, from 

Katsiyannis, A., Gage, N. A., Rapa, L. J., & MacSuga-Gage, A. S. (2020, May 8). Exploring the disproportionate use of restraint and seclusion among students with disabilities, boys, and students of color – advances in neurodevelopmental disorders. SpringerLink. Retrieved April 23, 2023, from 

Kern, L. (2020, July 7). CCBD’s position summary on the use of physical restraint procedures in … Retrieved April 25, 2023, from 

Kim, R. (2022, February 24). The restraint and seclusion of students with disabilities. Retrieved April 10, 2023, from 

Laku, I. M., Winarni, I., & Windarwati, H. D. (2020, May 16). The Effects of Restraint and Seclusion on Patients with Mental Disorder: A Systematic Review. Search | International Journal of Science and Society. Retrieved April 23, 2023, from 

Lombardo, C., & Abamu, J. (2019, December 5). A dreaded part of teachers’ jobs: Restraining and secluding students. NPR. Retrieved April 10, 2023, from 

Marshall, D. (2015, December 9). Trauma-informed care: Child safety without seclusion and restraint – COPAA. Council of Parent Attorneys and Advocates. Retrieved April 10, 2023, from 

Munson, E., Rocheleau, M., Putterman, A., & Seline, L. (2022, November 22). The little-known tactics injuring thousands of students at school. CT Insider. Retrieved April 10, 2023, from 

National Disability Rights Network. (2010, January). School is not supposed to hurt – NDRN. National Disability Rights Network. Retrieved April 10, 2023, from 

Nunno, M., Label, J., & Mohr, W. (2012, January). Restraint and Seclusion Use in U.S. School Settings: Recommendations From Allied Treatment Disciplines. Research Gate. Retrieved April 10, 2023, from 

The Substance Abuse and Mental Health Services Administration. (2010, March). Issue brief and restraint in Behavioral Health Services. Substance Abuse and Mental Health Services Administration. Retrieved April 10, 2023, from 

The United States Department of Justice. (2023, April 17). Seclusion enforcement – recent investigations. The United States Department of Justice. Retrieved April 23, 2023, from 

United States Department of Education. (2016, December 28). Dear colleague letter: Restraint and seclusion of students with … – ed. United States Department of Education. Retrieved April 10, 2023, from 

U.S. Department of Education. (2012, May 15). Restraint and seclusion: Resource document. Restraint and Seclusion: Resource Document. Retrieved April 10, 2023, from 

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