## Facts

- A nonprofit organization, New York City public school students, and their parents challenged New York’s school-finance system under the state constitution’s Education Article.
- Earlier rulings defined the constitutional requirement as the State’s duty to provide all children the opportunity for a “sound basic education,” understood as basic skills needed for civic participation.
- After a prior decision found New York City students were denied that opportunity due to inadequate funding, the State was directed to determine the actual cost of providing a sound basic education and implement reforms.
- The State developed an education reform plan and estimated that meeting the constitutional minimum for New York City required at least $1.93 billion (in 2004 dollars) in additional annual operating funds.
- The legislature did not enact proposed legislation incorporating the State’s plan.
- The trial court appointed referees to recommend a remedy; the referees proposed a substantially higher funding level, which the trial court confirmed and ordered implemented.
- On appeal, the dispute centered on whether the judiciary should accept the State’s estimate as constitutionally sufficient or impose the higher amount recommended by the referees.

## Issues

1. Whether the State’s estimate of at least $1.93 billion (2004 dollars) in additional annual operating funds for New York City schools was a reasonable calculation of the cost of providing the opportunity for a sound basic education.
2. Whether separation-of-powers principles required courts to defer to the State’s reasonable cost estimate rather than adopt a higher funding amount selected by the trial court based on referees’ recommendations.

## Decision

- The New York Court of Appeals held that the State’s $1.93 billion estimate (in 2004 dollars) was reasonable as a constitutional minimum for additional annual operating aid for New York City schools.
- The Court directed that the estimate should be accepted, subject to appropriate updating, and that courts should defer to it.
- The Court rejected the trial court’s adoption of the referees’ higher funding recommendation as exceeding the judiciary’s limited role in enforcing the constitutional minimum.
- The Court modified the Appellate Division’s order to reflect deference to the State’s reasonable estimate.

## Legal Principles

- The Education Article guarantees a judicially enforceable right to the opportunity for a sound basic education, defined as basic skills necessary for productive civic participation.
- The constitutional requirement sets a minimum floor; it requires an adequate opportunity, not equalized funding or guaranteed educational outcomes.
- In institutional reform remedies affecting budgeting and policy, the judiciary reviews the reasonableness of the political branches’ remedial actions and should not prescribe specific appropriations or operate as a super-legislature.
- When the State employs a reasonable methodology to estimate the cost of meeting the constitutional minimum, courts should defer to that estimate (with appropriate updates) rather than impose a higher figure based on judicial fact-finding preferences.

## Conclusion

The Court of Appeals reaffirmed the constitutional minimum right to a sound basic education and concluded that New York’s $1.93 billion (2004 dollars) estimate was a reasonable minimum level of additional annual operating funding for New York City schools, requiring judicial deference to the State’s updated estimate rather than court-imposed higher funding remedies.


Campaign for Fiscal Equity, Inc. v. State, 861 N.E.2d 50 (N.Y. 2006)