“…In contrast, as civil rights became a focus in the political and social reform campaigns intensifying in the 1960s and 1970s (e.g., the Women's Movement, Society for the Protection of Children), labeling became an extremely unpopular practice; many believed that labels were stigmatizing (Hallahan, Keller, & Ball, 1986;Kroll, 1984). According to Lichtenstein (1989), of the High School and Beyond project in New Hampshire, "definitions, as a whole, have plagued the field of special education for decades, and lack of consistency in usage has complicated numerous studies and tabulation efforts" (p. 503).…”