however, did not discuss what it would consider acceptable, leaving it to the state legislature to determine how to meet the constitutional requirement. In Wyoming, in a 1995 development in a court case that went back to 1980 (Washakie v. Herschler, 606 P.2d 310, Wyo. 1980), the supreme court ruled (Campbell v. State, 907 P.2d 1238, Wyo. 1995) that the legislature's response to its earlier decision had been deficient and ordered it to devise an acceptable remedy: "The legislature must first design the best educational system by identifying the 'proper' educational package each Wyoming student is entitled to have. . . . The cost of that educational package must then be determined and the legislature must then take the necessary action to fund that package. Because education is one of the state's most important functions, lack of financial resources will not be an acceptable reason for failure to provide the best education system. All other financial considerations must yield until education is funded."

Adequacy decisions in the courts do not always address the question of whether districts can provide education above the adequate level, but when they have, they have spoken with several voices. In Wyoming, local supplements are expressly forbidden. The Wyoming Supreme Court noted that "historical analysis reveals local control is not a constitutionally recognized interest and cannot be the basis for disparity in equal educational opportunity." The New Hampshire Supreme Court (Claremont v. Governor of New Hampshire, 703 A.2d 1353, N.H. 1997) and the North Carolina Supreme Court (Leandro v. State of North Carolina, No. 179PA96, 1997) both indicated that variations in spending resulting from local add-ons would be permissible so long as all districts are able to provide students with the constitutionally guaranteed minimum of opportunities. The finance system enacted in Kentucky in response to the 1989 ruling there allows local spending above the state-determined adequate level and so far has not faced legal challenge.

As happened in the wealth-neutrality litigation, not every state's high court has been receptive to adequacy arguments. In Illinois, where the state constitution's education clause explicitly requires the state to "provide for an efficient system of high quality public educational institutions and services," the supreme court rejected attempts by plaintiffs to evaluate whether the quality of education offered in many of their districts met that constitutional standard. According to the court, "questions relating to the quality of education are solely for the legislative branch to answer" (Committee for Educational Rights v. Edgar, 672 N.E.2d 1178, Ill. 1996). The high courts in Rhode Island and Florida relied on a similar rationale in rejecting adequacy-based claims. In Florida: ''appellants have failed to demonstrate . . . an appropriate standard for determining 'adequacy' that would not present a substantial risk of judicial intrusion into the powers and responsibilities assigned to the legislature" (Coalition for Adequacy v. Chiles, 680 So.2d 400, Fla. 1996). In Rhode Island: "what constitutes an 'equal, adequate, and meaningful' [education] is 'not likely to be divined for all



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