One of the reasons for ongoing court cases, increasingly mounted by people with disabilities themselves, is to ensure that implementation does not grind to a halt. The challenge continues.

In 1972, a federal court ruled that the failure of the District of Columbia school board to provide a publicly-supported education to all children with disabilities cannot be excused by the claim that there are insufficient funds (Mills v Board of Education).

The challenge in the first decade of the new century focused on determining the extent to which rights trump resources.