with developed economies. Later in the 1980s a more balanced public concern emerged, with both equity and excellence as goals. The increased focus on outcomes, the continued appeal of equal opportunity, and the shift in legal strategies as described by Enrich (1995) have increased the use of the concept of adequacy in educational analyses.

Adequacy could be defined in a number of ways. One definition specifies a level of resources that is sufficient to meet defined or absolute, rather than relative, output standards. In the words of William Clune (1995a:481), "adequacy refers to resources which are sufficient (or adequate) to achieve some educational result, such as a minimum passing grade on a state achievement test."

Lawyers generally make a distinction between adequacy and equity. To us the most useful distinction between adequacy and equity concepts is the focus on sufficient and absolute levels in adequacy and on relative levels or distributions in equity.

There is an ex ante definition of adequacy that involves specifying the kinds of outputs that must be achieved and even how they will be measured. The Kentucky court went the furthest in a legal specification by listing seven capacities that were defined absolutely and not relatively.33 In other court cases, such as Harper v. Hunt in Alabama, lawyers used state and national input and output regulations and standards to argue that Alabama's system, by comparison, was inadequate. The regulations and standards were ex ante ones, while the evidence from Alabama was ex post. Thus, adequacy is also an ex post idea, lending itself to quantification of results on various kinds of outcomes, such as test scores, graduation rates, attendance rates, college enrollment rates, etc. Sometimes the ex post measures are relative (to national ones for example), thus confusing a conceptual distinction between adequacy as absolute, external levels and equity, as relative distributions of levels.

The most recent New Jersey court case (Abbott v. Burke) and its remedy point the way in which the courts, through the concept of adequacy, may possibly join outputs, inputs, and processes. In New Jersey, the remedy has focused on resources, curricular offerings, and support services available to poor districts versus wealthy ones. While the idea is to provide an adequate education for children in poor districts, the method for achieving this involves a focus on details of programs, teacher quality, and technology. The New Jersey court has wrestled with the concept of adequacy since its first court case in the 1970s (Robinson v. Cahill).

Adequacy is a child-based concept. Conceptually, the unit could be the individual child, but litigators in state school finance cases have thus far used it as a district-level concept. The concept's unit would probably follow the funding patterns, so if funding were to go to schools, then the schools would be assessed for their adequacy on the basis of levels of achievement of students in those schools.

A distinction between adequacy and the way some equity concepts have

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