Seclusion, used broadly to include time-out (Bon & Zirkel, 2014), and other aversives, such as restraint, continues to be an active area of legal activity, particularly for students with disabilities. The September 2016 issue of "Communiqué" provided an update of the case law specific to school district use of seclusion (Zirkel, 2016) (EJ1200678). This 3-year update identified 24 pertinent court cases. For more user-friendly summarization, the analysis changed the previously more fine-grained claim rulings into three broad categories: (1) constitutional, such as Fourteenth Amendment substantive due process (SDP); (2) federal legislation, such as the Individuals with Disabilities Education Act (IDEA) or, more commonly in this specific context, Section 504 of the Rehabilitation Act (§ 504); and (3) state law, such as negligence or assault/battery. The overall outcomes distribution of these broad "claim category rulings" was: conclusively for the plaintiff -- 0%; inconclusive -- 51%; and conclusively for the defendant -- 49%. Upon conflation using the aforementioned best-for-plaintiff basis, the outcomes distribution using cases as the unit of analysis expanded the inconclusive category to 63%.