School Law Bulletin #2001/09

Leandro: Constitutional Adequacy in Education and Standards-Based Reforms

Sunday, July 1, 2001

The North Carolina Supreme Court in its now-famous Leandro1 decision recognized for the first time a right under the state constitution to a “sound basic education.” Three extensive rulings of a state superior court judge have given the first concrete dimensions to this right. This article examines the superior court rulings and looks at the legal aspects of North Carolina’s educational future.

The history of this country’s school finance litigation provides the broad context for the Leandro lawsuit. The narrower framework is the legal concept of “adequacy” and how it has evolved through various courts. The Leandro supreme court opinion, most especially the subsequent trial court rulings, adds a model of ad- equacy that dovetails almost perfectly with standards-based education reform. The trial court rulings also channel broad concepts of adequacy into an intense focus on the needs of at-risk children, including a mandate for preschool programs.

As in other school finance litigation, it is difficult to say when, if ever, the final chapter of Leandro will be concluded. More trial court rulings are expected in the lawsuit, and there is always the possibility of appeals. Nonetheless, it is time to begin charting North Carolina’s place in school finance litigation and the significant implications for this state in creating specific constitutional mandates for standards-based reforms and interventions for at-risk children.

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