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The term "English-language learner" was first used by Mark LaCelle-Peterson and Charlene Rivera in their 1994 study. He defined ELL students as students whose first language is not English, including both limited and higher levels of language proficiency. The term ELL emphasizes that students are mastering another language, something many monolingual students in American schools may never attempt outside of the limited proficiency gained from foreign language class requirements. In adopting the term, LaCelle-Peterson and Rivera gave analogies of other conventional educational terms. The authors believed that just as we refer to advanced teaching candidates as "student teachers" rather than "limited teaching proficient individuals," the term ELL underscores what students are ''learning'' instead of their limitations.<ref>{{cite journal |last1=Lacelle-Peterson |first1=Mark |last2=Rivera |first2=Charlene |title=Is It Real for All Kids? A Framework for Equitable Assessment Policies for English Language Learners |journal=Harvard Educational Review |date=1 April 1994 |volume=64 |issue=1 |pages=55–76 |doi=10.17763/haer.64.1.k3387733755817j7 }}</ref>
Since 1872, an English-only instruction law had been in place in the United States. It was not until 1967
Not long after the installment of [[Civil Rights Act of 1964|Title VII]], the "taxpayers revolt" came to fruition and California's Proposition 13 was drafted. It proposed funding cuts for large portions of California's public schools, backed by those who disapproved of immigrant progress. In opposition to this, cases like ''[[Castañeda v. Pickard|Castaneda v Pickard]]'' fought for educational equality and standards focused on developing ELL students, as well as an overall sound plan for school districts.<ref>{{Cite web|title=Sutori|url=https://www.sutori.com/story/sf-cess-historical-timeline-of-public-education-in-the-u-s--R4BQwQWU9qnFGZQk3x1WAbcN|access-date=2021-05-12|website=www.sutori.com|language=en}}</ref> An additional setback occurred in California in 1998 when Proposition 227 passed, banning bilingual education yet again. To combat this, education advocates in the Bay Area began to open all-inclusive schools to promote the acceptance of ELL students.<ref>{{Cite web|title=Small Autonomous Schools as a District Policy: The Oakland Plan {{!}} Coalition of Essential Schools|url=http://essentialschools.org/horace-issues/small-autonomous-schools-as-a-district-policy-the-oakland-plan/|access-date=2021-05-12|language=en-US}}</ref>
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