A focus on anything other than instruction undercuts the legal and moral rights of students with disabilities to an appropriate education and fails to produce substantive social justice. Differences among differences must be recognized to guarantee the civil educational rights to which people with disabilities are entitled. Instructionally-relevant differences include many disabilities, but they do not include such differences as skin hue, parentage, sexual orientation, national origin, and many other kinds of diversity. If special education's focus is inclusion rather than effective instruction of students with disabilities or if all differences are assumed to be equal and have the same remedy, then special education will one day be looked upon as having gone through a period of shameful neglect of students' needs.