The case of children with special needs, the federal courts have not talked about equal distribution of educational resources. There has been no effort that I know of for some time that seeks to build a case that the number of dollars expended per child should be equalized. To apply that argument seems to me to be as misguided as saying that public buildings do not need wheelchair ramps because the expense of building the ramps is not justified by the increase in participation in the civic affairs conducted within the building by individuals with mobility limitations. It is the access to the benefits generated by public funds that must be equitably distributed. If some who want to participate cannot until their needs are accommodated, then the distribution is inequitable until the accommodation is completed.
In terms of equitable distribution of special needs education opportunity, if education is so important that all children must be forced to engage in it, and so beneficial that large portions of state and local funds are devoted to it, then the opportunity to derive benefit from the forced participation must be equitably distributed. It is true that large sums of money could be saved if only those children whose intelligence and deportment falls within two standard deviations of the “mean”. That would create special schools for both those who were too far above and below the mean.