## Facts

- A nonprofit advocacy group, New York City public school students, and parents challenged New York’s public school financing system as applied to New York City.
- The claim arose under the New York Constitution’s Education Article requiring a statewide system of free common schools.
- A prior decision recognized a justiciable right to the opportunity for a “sound basic education” and required proof of a causal link between the funding system and any failure to provide that opportunity.
- After a lengthy bench trial focused on conditions in New York City schools, the trial court found students lacked the opportunity for a sound basic education and that the State’s funding scheme was a substantial cause; it ordered the State to reform funding.
- The intermediate appellate court reversed, defining “sound basic education” as little more than an eighth- or ninth-grade education and suggesting deficiencies were largely attributable to socio-economic conditions.
- The plaintiffs appealed to the New York Court of Appeals.

## Issues

1. Whether the State’s school financing system, as implemented in New York City, denied students the constitutionally required opportunity for a sound basic education.
2. What “sound basic education” means under the Education Article, including whether it requires more than an eighth- or ninth-grade education.
3. Whether plaintiffs proved a causal link between the funding system and any denial of the constitutional educational opportunity, notwithstanding socio-economic barriers.
4. What remedial directions a court may impose while respecting separation of powers.

## Decision

- The Court of Appeals reversed the intermediate appellate court and reinstated the trial court’s liability determination, with modifications to the remedy.
- The court held the State was failing to provide New York City students the constitutionally required opportunity for a sound basic education.
- The court rejected a minimal “eighth or ninth grade” standard and held the Constitution requires the opportunity for a meaningful high school education.
- The court found the record supported a causal link between the State’s financing system and the educational deficiencies in New York City schools; socio-economic conditions did not excuse the State’s constitutional duty.
- The court directed the State, by a specified deadline, to determine the cost of providing a sound basic education in New York City and to implement funding reforms and accountability mechanisms to ensure delivery of that education.

## Legal Principles

- The Education Article imposes a statewide, enforceable duty to provide all children the opportunity for a sound basic education.
- The constitutional minimum is the opportunity for a meaningful high school education providing basic literacy, calculating, and verbal skills necessary for productive civic participation, including voting and jury service.
- To establish a violation, plaintiffs must show both deprivation of the constitutional educational opportunity and a causal link between that deprivation and the challenged funding system.
- The State’s duty to provide the constitutional minimum education is not avoided by pointing to poverty or other socio-economic conditions.
- Courts may declare constitutional noncompliance and order the State to devise and implement corrective measures, while leaving specific policy design (such as funding formulas) to the political branches.

## Conclusion

The court held that New York’s school funding system, as applied to New York City, denied students the opportunity for a sound basic education and required the State to calculate the cost of providing a meaningful high school education and to implement funding and accountability reforms within a court-imposed timetable.


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