been conceived historically is adequacy's emphasis on outputs. The definition of adequacy begins with the idea of adequate performance by students, which requires specifications of performance in various kinds of output dimensions. But we believe that it is conceptually most useful to maintain the distinction between absolute levels (adequacy) and relative distributions of levels (equity). It is entirely possible for inputs, outputs, and outcomes to be equitable or inequitable, and it is possible for inputs, outputs, and outcomes to be adequate and inadequate.

Lawyers and judges have used the adequacy concept to apply to all districts in some cases (e.g., Kentucky, Massachusetts) and to poor, urban districts in others (e.g., New Jersey). William Clune is the most prominent advocate of using the idea to apply, in particular, to urban, poor districts.34 His writing on the topic has evolved from a description of adequacy that includes all children to one that targets poor children. He has even ventured a rough guestimate of the cost of adequate education in high-poverty schools: "the national average spending is about $5,000 per pupil, and the total adequacy package is about $5,000 per pupil above the typical budget of a high-poverty school, suggesting a total budget of $10,000 per pupil per year" (1993:391).

In a volume of the University of Michigan Journal of Law Reform, edited by Clune (1995b), several lawyers looked at applications of adequacy in three states—Alabama, Oklahoma, and Kentucky (Morgan et al., 1995; Grossman 1995; Trimble and Forsaith, 1995). Julie Underwood, in the same volume, interprets adequacy as a form of vertical equity, which is an interesting way to link the previous equity work with the current legal concept of adequacy: "adequacy from the perspective of 'vertical equity,' meaning that different students should be treated differently based on their special educational needs" (1995:493). Clune's definition, when targeted to high-poverty students, could be interpreted as a form of output vertical equity where differences among students are based on their family income.

Robert Berne's article, in the volume he co-edited on Outcome Equity in Education (1994), illustrates how outputs are related to poverty (and race) in one of the largest states. This article has been used as "evidence" by some for the need for adequacy-driven reform.

Legislators have also begun to use the concept of adequacy as they consider remedies, even in cases where the court's decision involved equity.35 Clune has outlined a research agenda that would help implement the adequacy concept (Clune, 1997), and some ongoing research on production functions and educational evaluation research of programs, such as Accelerated Schools and Success for All, is helpful to his framework, although not necessarily carried out with adequacy in mind.

Clune and others say that adequacy is a different concept from equity because it changes the focus from inputs to outputs and because it leaves behind the idea of equal resources for all. As we note above, in a broader view of equity, neither of these distinctions is essential, since outputs and outcomes can be accommodated



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