There is an ongoing, sometimes emotionally charged, debate in the field of special educa tion over which students are socially maladjusted and which are truly seriously emotionally (SED). debate stems from the requirement under the Education for All Handicapped Children Act (EHA), Public Law 94-142 (1975), to identify and provide appro priate special education and related services to all handicapped children including those who are handicapped by virtue of a serious emotional disturbance. However, the EHA Regulations state: The term [SED] does not include children who are socially maladjusted, unless it is determined that they are seriously emotionally disturbed (1977). Even though the EHA requires that a differentiation be made between the socially malad justed and the SED student, there is no guidance in the law as to what constitutes social maladjustment and how it differs from being seriously emotionally disturbed. Furthermore, there are no court cases to date which dictate or provide clarity on how to construe the meaning of the term social maladjustment. EHA Regulations (1977) do provide criteria for determining if a student is SED; however, these criteria do not differentiate social malad justment from being SED. Since there is no clear direction in the law as to how to distinguish SED from social mal adjustment, there are those who have put forth their views on the topic attempting to clarify the issue (DeYoung, 1984; Kelly, 1989; Kester, 1983; Slenkovich, 1983; Tibbetts, Pike, & Welch, 1986). These views — when adopted by school district personnel who make deci sions regarding eligibility for special education — can be quite influential in determining which particular students are identified as SED and which students are considered simply socially maladjusted and therefore not eligible for special education. If a student is eligible for special education services, a program of individually designed instruction and services to meet the student's needs must be made available (EHA Regulations, 1977). These services can include a classroom program with a small student-teacher ratio; a private school place ment if there is no appropriate public school program; psychological counseling or therapy including individual, group, or family therapy; or a variety of other services such as place ment in a residential program if these sen/ices are required to assist a handicapped child to benefit from special education (Irving Independent School District v. Tatro, 1983-1984). In addition, students who are identified as handicapped under the EHA cannot be expelled from school for behavior associated with their handicap (Doe v. Maher, 1985-1986; School Board Prince William County v. Malone, 1986-1987; S-1 v. Turlington, 1980-1981), and a change of their current educational placement requires the due process procedures speci fied in the EHA Regulations (1977) or injunctive relief by a court order (Honig v. Doe, 1988). Since services and protections are conferred or denied based on whether a student is designated as SED or socially maladjusted, fairness dictates that those making these deci sions base them on logically and empirically defensible conceptions of each category. Unfortunately, such is not the case. most prevalent view among those who write on this topic (Kelly, 1988; Kester, 1983; Los Angeles Unified School District, 1984) is that socially maladjusted students choose their maladjusted behaviors or feelings while students who are SED have no control over their behaviors or feelings. This view typically embraces the notion that certain types of