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Making Money Matter: Financing America's Schools
sufficient levels of academic or vocational skills to enable public school students to compete favorably with their counterparts in surrounding states, in academics, or in the job market.
The influence of the Kentucky case on other states was direct and apparent. Courts in Alabama, Massachusetts, and New Hampshire relied specifically on the Kentucky court's definition of an adequate education when providing guidance to their own state legislatures about crafting remedies for finance systems that had been declared inadequate.5
Other state courts developed their own specifications about what constitutes educational adequacy. In 1993, the Tennessee Supreme Court found that the state constitution required the education system to provide districts with sufficient funds to permit attainment of certain broadly defined educational outcomes: "The General Assembly shall maintain and support a system of free public schools that provides at least the opportunity to acquire general knowledge, develop the powers of reasoning and judgment, and generally prepare students intellectually for a mature life" (Tennessee Small School Systems v. McWherter, 851 S.W.2d 139, Tenn. 1993). Similarly, in 1994, the Arizona Supreme Court ruled that the state's system for funding school facilities was unconstitutional because certain districts lacked the resources necessary to maintain adequate school buildings (Roosevelt Elementary School District v. Bishop, 877 P.2d 806, Ariz. 1994). That decision, while limited to capital funding, also suggested that similar claims of adequacy might apply to school districts' operating costs. In 1995, the highest court in New York used a civic rather than an economic rationale to undergird its finding that the state is constitutionally obligated to create and maintain an education system that provides children with "the basic literacy, calculation, and verbal skills necessary to enable [them] to eventually function productively as civic participants capable of voting and serving on a jury . . . [and] minimally adequate physical facilities and classrooms . . . to permit children to learn" (Campaign for Fiscal Equity v. State of New York, 86 N.Y.2d 307, N.Y. 1995).6
Courts that mandate adequacy do not always themselves define the objectives that an adequate education system should serve. In 1997, the Ohio Supreme Court ruled that by permitting dramatic deficiencies in facilities, materials and supplies, and class sizes in some of the poorer school districts, the state had violated its constitutional duty to provide students with a "thorough and efficient" education system (DeRolph v. Ohio, 79 Oh.St.3d 297, Oh. 1997). The court,
See Alabama Coalition for Equity v. Hunt, published as appendix to Opinion of Justices, 624 So.2d 107 (Ala. 1993); McDuffy v. Secretary of Education, 615 N.E.2d 516 (Mass. 1993); and Claremont School District v. Gregg, 635 A.2d 1375 (N.H. 1997).
The high court decision in New York established the criteria against which funding levels will be appraised in a case currently scheduled to be tried in a lower court in late 1999.