Despite the fact that there has been much litigation with parents prevailing on the issue of inclusive preschools and much guidance from the Department of Education, this issue continues to be very prevalent. Schools persist in their lack of understanding that simply offering an self-contained early chldhood placement does not discharge their LRE obligations. More than 700,000 preschool children in this country, or 6.4% of the preschool population, have been identified as having special needs. And research has made it clear that many of these children will benefit from inclusive preschool placements where they can learn with and from their non-disabled peers. Four reviews of the literature undertaken since 1980 indicate that children with special needs placed in inclusive settings make at least as much progress on standardized measures of cognitive, language, motor, and social development as children in self-contained special education settings. According to researchers, inclusive placements afford preschool children with special needs learning opportunities that they will not have in a non-inclusive setting. In addition, some researchers feel that placement in non-special education settings is simply the right and ethical thing to do for these children and their families.