"During the writing of this text, the California State Department of Education (CDE) issued a memorandum, dated September 14, 2022, for all Special Education Local Plan Area Directors in the state (California Department of Education, 2022). The memorandum effectively reversed (in part) the prohibition against administering IQ tests to African-American students for any special education purpose in California schools. The memorandum was issued in response to an earlier 1986 CDE memorandum which expanded Judge Peckham's original 1979 decision in the Larry P. v. Wilson Riles trial. Peckham's decision prohibited the use of IQ tests for placing black students in programs for (what was then called at the time) the Educable Mentally Retarded - on the grounds that (in his determination) IQ tests were culturally biased against African American pupils. The CDE's 1986 memorandum expanded Judge Peckham's decision to prohibit the use of IQ tests for Black students in California for any special education purpose (including gifted identification; see California Association of School Psychologists, 1987; Frisby & Henry, 2015)"--