In this article, authors Carl Smith, Antonis Katsiyannis, and Joseph Ryan respond to Zirkel's most recent article, "The Law in the Special Education Literature: A Brief Legal Critique," published in this issue of "Behavioral Disorders." Smith, Katsiyannis, and Ryan begin their response by saying that "The Law in the Special Education Literature" is critical of an article that reviewed recent case law addressing several areas they believe to be significant in confronting the field of educating students with emotional or behavioral disorders (E/BD; Smith, Katsiyannis, & Ryan, 2011). Although the three of them agree with many of Zirkel's recommendations for improving the overall quality of legal articles in the field of special education, they take issue with Zirkel's analysis and at times refer to what they call "misrepresentation" of the article to make his point. They posit in summary that although Zirkel proposes a healthy ''constructive salutary diagnosis'' of the literature, he misses the mark by frequently striving to make his own point by often misstating others' claims.