Campaign for Fiscal Equity, Inc. v. State - 100 N.Y.2d 893, 769 N.Y.S.2d 106, 801 N.E.2d 326 (2003)

Rule:

The New York Court of Appeals has equated a sound basic education with the basic literacy, calculating, and verbal skills necessary to enable children to eventually function productively as civic participants capable of voting and serving on a jury. A sound basic education conveys not merely skills, but skills fashioned to meet a practical goal: meaningful civic participation in contemporary society. This purposive orientation for schooling has been at the core of N.Y. Const. art. XI, § 1 since its enactment in 1894.

Facts:

The fundamental value of education is embedded in the Education Article of the New York State Constitution by this simple sentence: "The legislature shall provide for the maintenance and support of a system of  free common schools, wherein all the children of this state may be educated" (NY Const, art XI, § 1). Plaintiffs, the Campaign for Fiscal Equity and others, claim that the State has violated this mandate by establishing an education financing system that fails to afford New York City's public schoolchildren the opportunity guaranteed by the Constitution. Plaintiffs additionally claim that the State's method of school funding in New York City violates their rights under United States Department of Education regulations pursuant to title VI of the Civil Rights Act of 1964 (42 USC § 2000d et seq.; 34 CFR 100.3 [b] [2]). The trial court found that the State had violated art. XI, § 1 and Title VI, provided a template for a sound basic education, and directed the State to put in place systematic reforms. The appellate division reversed. 

Issue:

Did the Appellate Division err to the extent that it founded a judgment for defendants upon a much lower, grade-specific level of skills children are guaranteed the chance to achieve?

Answer:

Yes.

Conclusion:

The court affirmed to the extent that plaintiffs' Title VI claims were dismissed and otherwise reversed. Plaintiffs had established a prima facie case of showing a causal link between the funding of New York City schools and students' educational opportunities. Tens of thousands of students were placed in overcrowded classrooms, taught by unqualified teachers, and provided with inadequate facilities and equipment. Test results and the number of students finishing school also showed that students were not receiving a sound basic education. The court modified the trial court's threshold guideline that the State ascertain the actual costs of providing a sound basic education in districts around the State and held instead that the State need only ascertain the actual cost of providing a sound basic education in New York City. Reforms to the current funding system had to ensure that every city school would have the resources necessary to provide a sound basic education.