Students with severe behavior problems can miss a great deal of instruction time.  If a teacher has a student with such problems, especially in an inclusive setting, they should anticipate and plan for incidences in the classroom.  However, if teachers have insufficiently planned and the student is not receiving the appropriate instruction, have these students been denied the education that they should have.  I know, I know; you want to say, "How can you educate someone that won't let you?"  I agree; it's tough.  This student could be in the classroom but be so disengaged that they are not getting any classroom benefit; and if you try to engage, then you fuel the fire of the behavior that you are trying to avoid.  Yet, if they are sent to detention or suspension, they are not receiving anything.  What shall we do?