dards. In the past, debates over equity focused on comparisons among children and districts and how well they fared relative to each other. Adequacy appears to demand the setting of absolute standards rather than defining equity in terms of the relative performance of school finance systems.

Adequacy may also result in different groups taking center stage as the focus of special interest. William Clune, a prominent legal scholar (and original member of the Coons team that developed the wealth-neutrality standard for school finance equity), illustrates in the development of his own thinking one direction that adequacy might take. From early descriptions of adequacy that included all children, his writing has evolved to define adequacy as a concept to be applied especially to urban, poor districts and to high-poverty students (Clune, 1995).

It is in determining how adequacy can be evaluated that there is perhaps the least consensus on defining the concept. Much of the remainder of this chapter assesses the various options being explored by courts and states as they attempt to apply an adequacy standard to school finance systems. In practice the distinction drawn here between older measurements of equity using distributional bases and adequacy as an absolute measure is frequently blurred when it comes to defining how the adequacy of a finance system should be evaluated, probably because concepts using absolute rather than relative standards are only now being developed. Some courts (e.g., Harper v. Hunt in Alabama2) have found the state finance system inadequate using comparisons with state and national input and output regulations and standards. Sometimes the ex post tests of adequacy are also comparative rather than absolute in nature, as when outcome measures such as test scores or graduation rates are compared with national statistics.

Developing absolute standards of adequacy (both ex ante and ex post) requires answers to two questions: Adequacy of what? How much is adequate? Strike (1988) has pointed out that the philosophical debate over distributive justice that has taken place over the 30 years since the publication of Rawls's A Theory of Justice (1971) provides some framing ideas for considering these questions.

In seeking an alternative to utilitarianism, which holds that just policies are those that produce the greatest good for the greatest number and defines "good" as happiness or utility, Rawls (1971) sought plural indices of social welfare rather than continuing to rely on happiness or utility. He developed the notion of "primary goods": things that a rational person wants whatever else that person wants, desirable because they are means to leading a wide range of different kinds of lives. He listed the primary goods as rights and liberties, powers and opportunities, income and wealth, and self-respect.

The Rawlsian theory of primary goods suggests a way of approaching an-


 Consolidated with Alabama Coalition for Equity v. Hunt, published as appendix to Opinion of Justices, 624 So.2d 107 (Ala. 1993).

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