While there were court decisions in the 1970s in New Jersey, Washington, and West Virginia that gave attention to the adequacy as well as the wealth neutrality of school finance systems, it was the Kentucky Supreme Court's decision in 1989 overthrowing the entire state education program that galvanized the shift toward adequacy in courthouses and statehouses. Between 1989 and mid-1998, courts in Alabama, Massachusetts, New Hampshire, New Jersey, New York, North Carolina, Ohio, Tennessee, and Wyoming also have ruled that their state constitutions' education clauses guarantee students an adequate level of educational opportunities that should allow them to achieve certain desired educational outcomes. In addition, claimants in Arizona won an adequacy case concerning capital costs of school construction; and adequacy-based lawsuits were pending in mid-1998 in Louisiana, Minnesota, Pennsylvania, and South Carolina.

Part of the reason that the 1970s decisions in New Jersey, Washington, and West Virginia did not spur more adequacy cases was that it was not evident at the time that the courts were doing anything significantly different than they did in traditional wealth-neutrality cases. Kentucky, however, clearly marked a sea change. In Rose v. Council for Better Education, 790 S.W.2d 186 (Ky. 1989), the state supreme court used ''efficiency" language in the constitution's education clause4 to declare the entire educational system inadequate and unconstitutional. The court established the objectives of an adequate education, proclaiming that it would provide students with the opportunity to develop at least the following seven capabilities:

  • sufficient oral and written communication skills to enable students to function in a complex and rapidly changing civilization;

  • sufficient knowledge of economic, social, and political systems to enable the student to make informed choices;

  • sufficient understanding of governmental processes to enable the student to understand the issues that affect his or her community, state, and nation;

  • sufficient self-knowledge and knowledge of his or her mental and physical wellness;

  • sufficient grounding in the arts to enable each student to appreciate his or her cultural and historical heritage;

  • sufficient training or preparation for advanced training in either academic or vocational fields so as to enable each child to choose and pursue life work intelligently; and


 The Kentucky ruling cited Section 183 of the state constitution, which calls on the state "to provide an efficient system of common schools throughout the Commonwealth."

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