Bullying is a major issue and has garnered closer public attention with the tragedy at Columbine High School in 1999. There is no question that bullying is endemic on our school campuses and impacts all those involved. No child should be bullied and the schools have an affirmative duty to prevent and address bullying. When a victim of bullying is a child with a disability, the failure of the school to properly address the problem can be seen as a denial of a free and appropriate public education (F.A.P.E.).