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in teacher preparation programs and in professional development activities so that students and in-service music educators will better be able to negotiate the increasingly litigious educational world

egal issues facing music educators remain one of the least important topics of conversation for preservice music educators.

how active they have been willing in inserting their decisions in school-based assessment policy.

Historically, courts have been somewhat deferential to school leaders and have not been willing to hear too many cases dealing with educational law and assessment.

Based on this decision, courts would be more likely to defer to school leaders in making their final rulings.

distinguish issues are purely academic from those that are purely disciplinary.

s. Three basic factors must exist for constitutional due process to exist: a student must have proper notice, a student must be given the chance to be heard, and the hearing should be conducted in a fair manner

The court decided that denying a student of education, regardless of the amount of time, could not be considered an inconsequential thing and claimed that a person’s right to education was equitable to the rights to liberty and property. In the majority decisions, the Supreme Court justices argued:

The US Supreme Court’s decision in Goss created the opportunity for students, parents, and their representatives to challenge not only disciplinary suspensions and expulsions but also other decisions by school officials that may affect liberty or property rights, including grades and grading policies.

that of courts taking a more active role and deferring less often to school leaders.

Because of these high stakes (real or imagined),

little more than attendance and participation, others feel that grades must represent academic achievement and that “allowing non-academic factors to affect academic grades distorts the truth about students’

however, because music is addressed minimally in these laws, their enactment has had minimal direct impact on music educators’ assessment practices.

Research  Teaching students to research is a common standard across all grade levels, elementary, middle school, high school, and beyond. Diigo excels as a research tool: Students can save relevant websites to lists in their Diigo student accounts. Each saved bookmark captures the URL and a screenshot, and can be searched later. Students can highlight important information right on the website, using Diigo. Later, when students return to the website, they find the reason they saved the bookmark in the first place. Students can use virtual sticky notes to summarize the important points of information from the website. This activity will mimic the time-tested procedure of using note cards to summarize and organize research projects. Students working on similar topics can create and join groups in order to collaborate. Later, when students need to document their sources, Diigo can be used to recall website URLs for citing sources.

It is hoped that the themes that emerge by setting twentieth and twenty-first century professional composers' accounts of certain compositional experiences or phases of their creative processes against one another will provide a philosophical framework for teaching composition.

Furthermore, the knowledge of how professional composers compose offers the potential of finding the missing link in music education; that is, the writing of music by students within the school curriculum

Such involvement may deepen their understanding of musical relationships and how one articulates feelings through sounds beyond rudimentary improvisational and creative activities currently available

raw philosophical implications for music composition in schools from recognized composers' voices about their individual composing realities

It is hoped that the direct access to these composers' thoughts about the subjective experience of composing Western art music in the second half of the twentieth and the beginning of the twenty-first century may also promote the image of a fragmented culture whose ghettoization in music education is a serious impediment to the development of a comprehensive aesthetic education.

n other words, there is a striking unanimity among composers that the role of the unconscious is vital in order to start and/or to complete a work to their own satisfaction.

I need . . . to become involved, to come into a state where I do something without knowing why I do i

This is a complex problem and difficult to explain: all that one can say is that the unconscious plays an incalculable rol

Nonetheless, these self-observations about the complementary roles of the unconscious and conscious aspects of musical creativity do not cover the wide range of claims in psychological research on creativity

I strongly believe that, if we cannot explain this process, then we must acknowledge it as a mystery.25 Mysteries are not solved by encouraging us not to declare them to be mysteries

When Ligeti was commissioned to write a companion piece for Brahms' Horn Trio, he declared, "When the sound of an instrument or a group of instruments or the human voice finds an echo in me, in the musical idea within me, then I can sit down and compose. [O]therwise I canno

Extra-musical images may also provide the composer with ideas and material and contribute to musical creativity.

ome composers need to have something for it to react against.38 Xenakis, however, asserted that "all truly creative people escape this foolish side of work, the exaltation of sentiments. They are to be discarded like the fat surrounding meat before it is cooked."

as, as these examples show, dreams can also solve certain problems of the creative process.

In other words, to compose does not mean to merely carry out an initial idea. The composer reserves the right to change his or her mind after the conception of an idea.

n sum, self-imposed restrictions or "boundary conditions"55 seem to provide composers with a kind of pretext to choose from an otherwise chaotic multitude of compositional possibilities that, however, gradually disappears and gets absorbed into the process of composition which is characterized by the composers' aesthetic perceptions and choices.

Therefore, it is not surprising that influences from the musical world in which the composer lives play an important role in the creative process

Thereby the past is seen as being comprised by a static system of rules and techniques that needs to be innovated and emancipated during the composers' search for their own musical identity.

I strongly suggest that we play down basics like who influenced whom, and instead study the way the influence is transformed; in other words: how the artist made it his own.

Nothing I found was based on the "masterpiece," on the closed cycle, on passive contemplation or narrowly aesthetic pleasure.61

Furthermore, for some composers the musical influence can emerge from the development of computer technology.

If a general educational approach is to emerge from the alloy of composers' experiences of their music creativity, it rests on the realization that the creative process involves a diversity of idiosyncratic conscious and unconscious traits.

After all, the creative process is an elusive cultural activity with no recipes for making it happen.

n this light, the common thread of composers' idiosyncratic concerns and practices that captures the overall aura of their music creativity pertains to (a) the intangibility of the unconscious throughout the compositional process,68 (b) the development of musical individuality,69 and (c) the desire to transgress existing rules and codes, due to their personal and social conflict between tradition and innovation.70

In turn, by making student composers in different classroom settings grasp the essence of influential professional composers' creative concerns, even if they do not intend to become professional composers, we can help them immerse in learning experiences that respect the mysteries of their intuitions, liberate their own practices of critical thinking in music, and dare to create innovative music that expresses against-the-prevailing-grain musical beliefs and ideas.

Therefore, it is critical that the music teacher be seen as the facilitator of students' compositional processes helping students explore and continuously discover their own creative personalities and, thus, empowering their personal involvement with music. Any creative work needs individual attention and encouragement for each vision and personal experience are different.

After all, the quality of mystery is a common theme in nearly every composer's accoun

Failing this, musical creativity remains a predictable academic exercise

Music teachers need to possess the generosity to refuse to deny student composers the freedom to reflect their own insights back to them and, in turn, influence the teachers' musical reality

Indeed, it is important that music teachers try to establish students gradually as original, independent personalities who try to internalize sounds and, thus, unite themselves with their environment in a continuous creative process.

Music teachers, therefore, wishing student composers to express and exercise all their ideas, should grant them ample time to work on their compositions,

n sum, music knowledge or techniques and the activation of the student composers' desire for discovery and innovation should evolve together through balanced stimulation.

While music creativity has been a component of music education research for decades, some of the themes arising from professional composers' experiences of their creativity, such as the significance of the unconscious, the apprehension towards discovering ones' own musical language, or the personal and social tension between tradition and innovation, among others, have not been adequately recognized in the literature of music education

By doing this, I strongly believe that musical creativity in general and composing in particular run the risk of becoming a predictable academic exercise

which merely demands problem-solving skills on the part of the student composers (or alleged "critical thinkers").

. On the other hand, only few music educators appear to draw their composer students' attention to the importance of the personal and social conflict between staying within a tradition or code, even if it is the Western popular music tradition, and breaking new ground at each step in the creative process and, possibly, shaping new traditions or codes.

Culture is a precious human undertaking, and the host of musics, arts, languages, religions, myths, and rituals that comprise it need to be carefully transmitted to the young and transformed in the process."85

Nevertheless, further research is needed in which women's voices can be heard that may offer an emancipatory perspective for the instruction of composition in education which will "challenge the political domination of men."