the New Hampshire and North Carolina Supreme Courts, which would allow for local variation in spending so long as all districts have access to a high-minimum level of adequacy.

Not every state's high court has been receptive to adequacy arguments. In Illinois, where the state constitution's education clause explicitly requires the state to "provide for an efficient system of high quality public educational institutions and services," the Illinois Supreme Court rejected attempts by plaintiffs to evaluate whether the quality of education offered in many plaintiff districts met that constitutional standard. According to the court, "questions relating to the quality of education are solely for the legislative branch to answer" (Committee for Educational Rights v. Edgar, 1996). The high courts in Rhode Island and Florida relied on a similar rationale in rejecting adequacy-based claims (Coalition for Adequacy v. Chiles, 680 So.2d 400, Fla. 1996: ''appellants have failed to demonstrate … an appropriate standard for determining 'adequacy' that would not present a substantial risk of judicial intrusion into the powers and responsibilities assigned to the legislature"; City of Pawtucket v. Sundlun, 662 A.2d 40, R.I. 1995: "what constitutes an 'equal, adequate, and meaningful' [education] is 'not likely to be divined for all time even by the scholars who now so earnestly debate the issues'").

As we explained earlier, some civil rights advocates see adequacy cases as a way to improve the education of inner-city, minority children even if they attend largely all-minority schools. But now a new twist on the adequacy theory has been proposed in two Minnesota cases seeking, among other substantive education remedies, racial integration. Advocates there have sought to have an adequate education defined in such a way as to include a racially integrated education (e.g. Minneapolis NAACP v. State of Minnesota and St. Paul School District v. State of Minnesota, both filed 1996). If this approach were to succeed, it would provide a way, through the state constitution's education clause, to remedy non-intentionally created racial isolation, a situation that the federal constitution—through the equal protection clause—would not redress. That the adequacy theory can be advanced on behalf of these two very different educational visions underscores its plasticity. This divergence in approach also exposes the understandable division of opinion within minority communities: some continue to aim for integrated schools even if this means having many children attend school far from home, while others want to concentrate on improving local schools and not risk that precious resources wind up being spent merely for transportation and not education.

Legislative Responses To Educational Adequacy Decisions

An important consequence of moving to an educational adequacy-based theory is that it may require legislative solutions that go far beyond matters of



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