In the Cerra v. Pawling School District case, the court noted that “when a learningdisabled child is in a mainstream class, ‘the attainment of passing grades and regular advancement from grade to grade’ will generally constitute evidence of satisfactory progress.” Other courts have ruled that these factors are just issues to consider and not necessarily determinative of progress, particularly when the student’s grades are modified. What weight should a court place on student grades and the fact that the student is passing from grade to grade? What kind of information may show that a student with passing grades is not making satisfactory progress under the IDEA?