In this paper the role of qualitative research in special education is examined. The implications of an earlier naturalistic study are cited, an important one being the tendency in the literature to oversimplify the naturalistic paradigm; and the case is made that implementing such a paradigm is a "labor intensive" approach to research in which no short cuts are possible. The experience of the creators of the earlier study shows the importance of an "emergent design principle" by which the research expands to include a larger field of interest as needed. Stringent requirements for creating an audit trail and for translating field notes immediately are described. It is concluded that the naturalistic inquiry method may be best suited for situations in which a person wants to understand what is occurring in complex human systems and is willing to expend great time and effort. (CL)