time even by the scholars who now so earnestly debate the issues'" (City of Pawtucket v. Sundlun, 662 A.2d 40, R.I. 1995).

Another possible dimension of an adequate education has been proposed in two Minnesota cases seeking, among other substantive education remedies, racial integration.7 Advocates there have sought to have an adequate education defined in such a way as to include a racially integrated education. If this approach were to succeed, it would provide a way, through the state constitution's education clause, to remedy unintentionally created racial isolation, a situation that the federal constitution—through the equal protection clause—would not redress.


The adequacy movement is comparatively new; there is limited evidence to date on what is required to reform school finance systems on this basis. Early indications can be gleaned from a review of state responses so far.

The Kentucky example proved that moving to educational adequacy as the basis for reform may require legislative solutions going far beyond matters of school funding. The fact that Kentucky's legislature promptly enacted a comprehensive statewide education reform package in response to the court's decision is encouraging but, given particularly favorable political incentives in the state (Carr and Fuhrman, 1999), probably not reflective of how other states may respond to similarly far-reaching court mandates. The Kentucky Education Reform Act (KERA) recreated the state's entire elementary and secondary education system, encompassing finance, governance and program changes; increased school district revenue by 34 percent (19 percent adjusted for inflation) between 1990 and 1993; and reduced disparities in spending among districts and in the relationship between district wealth and spending (Adams, 1997). KERA also featured a strong accountability program based on a new assessment system and providing financial rewards for exceptional performance and significant sanctions for poor performance.

Legislative efforts to comply with adequacy rulings in states other than Kentucky have been noticeably more contentious. Chapter 3 introduced the long saga of school finance litigation in New Jersey, which had adequacy overtones from its early days and assumed a more explicit adequacy cast in the 1980s, when school finance reform advocates filed a new suit on behalf of the children in 29 of the state's poorest districts. The Abbott v. Burke, 575 A.2d 359 (N.J. 1990), decision decreed that the children in the 29 districts identified in the court case as special needs districts must have educational opportunities equal to those of


 See Independent School District No. 625, St. Paul, Minnesota v. State of Minnesota, No. 62-C2-009356 (Minn. 2nd Dist. Ct. filed Sept. 19, 1996) and Minneapolis Branch of NAACP and Lee Xiong, et al., v. State of Minnesota, No. MC 95-014800 (Minn. 4th Dist Ct. filed Sept. 19, 1995).

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