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This is true but in many areas there are many children who fall through the cracks and many school districts who do not adhere to the special education requirements.
I'm really too tired to go back and look for the actually post, however, IIRC, it was said that Johnny "graduated" from a regular high school. It is very possible that he was in special education classes within that school (not that I don't trust the family but this was a while ago and most of the information is from his sister who is clearly not communicating well) and diplomas used to be a lot less difficult to get, i.e. there were some states where they were really "certificates of attendance" rather than true diplomas. I think this was still done is some states even in recent years.
ETA: sorry for the run-on...I really am tired. Until tomorrow!
He may have fallen throught he tracks, but I do not know of any school district that did not adhere to this federal law at the time Johnny would have graduated.