Campaign for Fiscal
Equity v. State of New York, 100 N.Y.2d 893, 801
N.E.2d 326, 769 N.Y.S.2d 106
Decided
June 26, 2003
The case began in 1993 when the
Campaign of Fiscal Equity (CFE) , a public interest group, filed a
constitutional challenge to the state school funding system. They claimed that the states’ school finance
system does not provide sufficient funds to New York City public schools and denies its
students their constitutional right to a “sound basic education” under the New
York State Constitution. The Education
Article of the New York Constitution states that “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.”
The decision in this case defined the meaning of this Education Article
and determined that the New York City
public school system is in violation.
As this case moved up and back
through the New York
State court system, there were various formulations of what the state must
do in order to comply with the constitutional requirement. At one point, the Appellate Division, an
intermediate level appellate court, decided that the State Constitution only
requires that schools provide the opportunity to learn at an 8th or
9th grade skill level. The
New York State Court of Appeals rejected the 8th grade standard and
found that a sound basic education consisted of “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.”
All students in New York
public schools therefore have the right to an “opportunity for a meaningful
high school education, one which prepares them to function productively as
civic participants.”
The Court
of Appeals held that the New York City
public schools violated this right to education provided by the New York State
Constitution. It noted the evidence
presented at trial of (1) what the
schoolchildren in our modern society need in order to function productively as
civic participants; (2) “inputs” in the education system in New York City--
teaching and teacher quality; school facilities and classrooms with respect to
environment and class size; and instrumentalities of learning such as
textbooks, classroom supplies, and computers, and
(3) “outputs” in the system – school completion rates and
test scores of its students.
In every area examined, New York City schools
were below average compared with the rest of the state. But in order for the
plaintiff CFE to prove its case, it had to show that the failure to provide a
sound basic education was related to the present funding system. The Court of Appeals found that the CFE did
establish a “causal link between the present funding system and any proven
failure to provide a sound basic education.”
New York City
schools were shown to have the most student need and the highest local cost,
yet the lowest per-student funding from the state and the worst results. By analyzing the “inputs” into the schools
---teacher, facilities, books, and the like – and the “outputs” of the
students’ tested performances afterwards, the Court found a correlation between
the state funding scheme and the failure of the New York City schools to provide a sound
basic education to its students. It held
that state aid to the New York City
schools must be increased where the need is high and the local ability to pay
is low.
Learning Activities
Terms to Know
-
Appellate court
-
Civic participants
-
New
York State
Constitution Education Article
-
Sound basic education
Compare and Contrast
The New York State
Court of Appeals decided Paynter v. New York
(100 N.Y.2d 434, 797 N.E.2d 1225, 765 N.Y.S.2d
819) on the same day that it decided this case, Campaign for Fiscal
Equity v. State of New York. Both cases apply the Education Article of the
New York State Constitution to situations where students suffer from very low
graduation rates and poor test scores. Yet, the results in each were
different. Explain why the Court of
Appeals decided that the rights of students were violated in the CFE case but
not in Paynter.
Analytical Thinking
The dissenting opinion by Judge Read in the CFE
case disputed that plaintiffs had shown a causal connection between the level
of state aid and the deficiencies in the New York City Public schools. He writes that “educational deficiencies are
not always attributable to the lack of money or necessarily cured by the
infusion of more funds. A wide variety of non-financial factors may contribute
to academic failure.” What would be some
of these non-financial factors? Do you
agree with Judge Read?
Research Project
New York
State funds its schools
through a combination of state and local taxes.
What are other ways that States in the United States fund its public
schools? What about other nations’
education funding schemes?
Interesting
Note: The CFE case reappeared at the
Court of Appeals in 2006 on the issue of how much money the state must spend to
meet the requirements of the Education Article.
A Webcast of the oral argument in this case can be found at
http://www.courts.state.ny.us/ctapps/crtnews.htm.