This essay provides a two-pronged critical assessment of a subset of the literature on racial disproportionality in special education: that which aims to estimate racial disparities among otherwise similar children. This body of research has shown that Black students are less likely than "comparable" White students to receive special education, and has been interpreted by many to mean that current policies meant to reduce Black over-representation may be exacerbating inequality. Our essay argues that this subset of research has fundamental limitations in its covariate adjustment practices and its data quality, making "under-representation" findings questionable. We argue that caution and further study are needed for an accurate understanding of the nature of racial disproportionality in special education.