In the case of Wheeler et al. v. Barrera et al., 1973, the U.S Supreme Court was tasked with determining whether Missouri's policy of providing special education services only to residents violated the Equal Protection Clause of the Fourteenth Amendment. The plaintiffs were children from Arkansas who lived in a residential treatment center in Missouri and sought access to these services. The court ruled that while states have substantial interest in limiting benefits to their own citizens, they must still meet certain standards under equal protection laws when dealing with non-residents. The Supreme Court held that it is not inherently unconstitutional for a state to limit certain benefits - including educational ones - solely to its residents; however, such restrictions are subject to scrutiny under equal protection principles and may be deemed unlawful if found unreasonable or arbitrary. Furthermore, it was determined that federal law did not mandate cross-border arrangements for special education between states as argued by plaintiffs based on Elementary and Secondary Education Act provisions. This decision affirmed lower courts' rulings denying relief but remanded the case back for further proceedings consistent with this opinion regarding potential violation of equal protection rights due its arbitrariness or unreasonableness.

In the dissenting opinion for Wheeler et al. v. Barrera et al., Justice William O. Douglas argued that the majority's decision was a misinterpretation of Title I of the Elementary and Secondary Education Act (ESEA). He contended that ESEA required states to provide comparable services to both public and private school students, not just make those services available as determined by state law or local policy. He believed this interpretation would lead to unequal treatment between public and private schools, contrary to Congress' intent when passing ESEA. Furthermore, he disagreed with the majority’s view on judicial review in such cases; he asserted courts should have an active role in ensuring compliance with federal laws like ESEA rather than deferring entirely to state educational agencies’ decisions.