 The dilemma may not be insurmountable. The movement for universal design in education aims to refashion classrooms and teaching practices to encourage the participation of all students. To the extent that the movement is successful, it will minimize the need for “special education” (Biklen 1992; Gartner and Lipsky 2002; Lipsky and Gartner 1996). Law and public policy must think creatively about ways to solve this dilemma so that the stigma they seek to eliminate is not in effect reinforced. Success in resolving the dilemma of difference may reduce the importance of disability identity for justice. If disability is simply a characteristic to be taken account of in social arrangements, it could become as significant or insignificant as height or aptitude.