Hawaii, like all but four states, is experiencing an extreme fiscal crisis. As a partial response, Hawaii and its teacher’s union agreed to a contract for the 2009-2010 school year with 17 fewer days, dubbed “Furlough Fridays.” This cut stood to save the state thousands of dollars, but also meant that all students in Hawaii would lose approximately 10% of instructional time. Parents of students with disabilities sued to prevent the state from implementing this plan, arguing the lost time was a change of placement and violated IDEA’s stay put provision. The State went forward with the cost cutting measure, which began regardless of the suit in October of 2009. Late last week, the Ninth Circuit disagreed with parents and ruled that “system wide changes are not meant to be covered by IDEA’s stay put provision.”