There have been four major court decisions affecting bilingual education: Lau v. Nichols, Serna v. Portales, Aspira v. the New York Board of Education and Keyes v. Denver School District No. 1. Lau v. Nichols was an action brought by non-English-speaking Chinese-origin students claiming to be denied an education because they could not comprehend the language in which they were being taught. After two appeals, the Supreme Court found in favor of the students under the 1964 Civil Rights Act, without prescribing a specific remedy. However, in Serna v. Portales the Circuit Court required bilingual education as a solution when a "substantial group" is involved. The decision in Aspira v. the N.Y. Board of Education required testing of students in English and their native language to determine who should receive bilingual education. The Keyes decision specified that students should receive both instruction in English and native-language instruction in other subjects until they are competent in English. It seems clear that school systems must provide non-English-speaking students with special English instruction and that they must give these students an opportunity to learn the other school subjects as well. HEW's Office of Civil Rights has issued guidelines for eliminating illegal educational practices; these involve pupil evaluation and placement in the proper type of language program. (CHK)