The special education for special needs children went through man y phases before they were recognized by the court systems. The first phase of special education is the largest span of time. The foundation Phase was from 1800 to 1930, children who had any sign of learning problems were labeled as being dumb, retarded, and even brain injured. The reason students would have been labeled as brain injured is because of studies done on war victims and soldiers of war. Many soldiers had head injuries and the way they acted related vary similarly to the way "brain injured" students acted. At this time period researchers and doctors located the area of the brain related to language, or the language function of the brain.Then there was the transition Phase began in 1930 and lasted until 1960. This phase had some turning points in the way "brain injured" children were taught. Researchers developed instruments for assessments, analyzed specific types of learning problems and also presented a plan for teaching "brain injured" children. At this stage the labeling of the children with learning problems was not as harsh as "brain injured". The students were called "children with minimal brain dysfunction" Then the turning phase for the education of students with learning problems was later called the Integration Phase which lasted from, 1960's to 1980's.