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US Food and Drug Administration (FDA) issued a federal ban on electrical stimulation devices (ESDs) used by a Massachusetts special needs school to condition students into changing behavior deemed self-injurious or aggressive US Court of Appeals for the District of Columbia, in a 2-1 decision, overturned the FDA's 2020 ESD ban granting the Judge Rotenberg Educational Center allowance to resume delivering electric shocks to both child and adult students at the facility..