youths, some of their advocates too have concluded that school finance litigation might be a promising substitute (Tatel, 1992). But, as noted earlier, for needy children attending high-cost, urban schools, school finance litigation would be far more attractive if it could be cast more widely than the conventional wealth discrimination approach.

The Embrace of Adequacy

These forces together have brought many school finance reformers around to a new view of what states should do. Rather than the over "Robin Hood" solution promised by school finance equity litigation, perhaps it would be wiser to direct the main reform effort at getting the states to assure what we believe is best termed a "high-minimum quality education for all."

As spelled out by William Clune (who abandoned the Coons team for this new approach) and others, a state-guaranteed high-minimum is most often what is meant by an "adequate" education (Clune, 1994; see Chapter 2 in this volume). In funding this high-minimum, the system would specifically take into account the varying needs of different types of pupils. It would also recognize that individual schools (or districts) face differing costs. Beyond those based on differences in the cost of living, the high-minimum approach would probably also recognize that some communities will have to pay more to attract equally good teachers to teach their needier and lower-achieving students. It would probably also recognize the benefit some students gain from having higher-achieving classmates and other intangibles that enable their school to provide a good education, and in turn would somehow compensate for the lack of those advantages in other schools. In other words, the high-minimum approach focuses on what would be needed to assure that all children have access to those educational opportunities that are necessary to gain a level of learning and skills that are now required, say, to obtain a good job in our increasingly technologically complex society and to participate effectively in our ever more complicated political process.

In this respect, the adequacy approach decidedly reflects a shift of the sort we saw in the history of the race cases, where the Supreme Court became increasingly concerned with what the real educational opportunity was, and not merely the easily measured input factors. But as noted above, an expanded equity paradigm, at least in principle, could also accommodate these same adjustments.

What is most distinctive about the adequacy approach is that, unlike the traditional school finance cases, it does not rest on a norm of equal treatment. Indeed, the adequacy cases aren't about equality at all, except in the sense that all pupils are equally entitled to at least a high-minimum. In other words, adequacy is not a matter of comparing spending on the complaining group with spending on others. It is rather about spending what is needed (and its focus is in some respects more on the school or the pupil than on the district).

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