## Facts

- Students, school districts, and education advocates challenged Ohio’s elementary and secondary public-school funding system as violating Article VI, Section 2 of the Ohio Constitution, which requires a “thorough and efficient system of common schools.”
- In an earlier decision, the Supreme Court of Ohio held the financing system unconstitutional and required legislative reform while retaining jurisdiction.
- The General Assembly enacted changes, including a per-pupil “base cost” formula and facilities-related programs, and the case returned for review of whether the revisions cured the constitutional violation.
- The revised base-cost calculation relied on 127 “model” districts identified as meeting at least 20 of 27 academic-performance standards.
- The calculation excluded the top and bottom 5% of districts by income and property wealth through “wealth screens.”
- The methodology included data-handling and rounding choices that permitted inclusion of districts that did not satisfy the stated performance criteria.
- The state used an “echo effect” approach that selected the lower of two years of spending data, tending to reduce the estimated base cost.

## Issues

1. Whether the revised school-funding system complied with Article VI, Section 2’s requirement of a “thorough and efficient system of common schools.”
2. Whether the base-cost methodology, including wealth screens and expenditure-selection choices, produced an arbitrary or inadequate estimate of the cost of an adequate education.
3. What remedies were appropriate under the court’s continuing jurisdiction, including limits on permissible funding-calculation methods and the timing of any required funding increases.

## Decision

- The Supreme Court of Ohio held the revised funding system remained unconstitutional under Article VI, Section 2.
- The court concluded the base-cost methodology required revision because key features depressed the calculated cost of providing an adequate education.
- The court directed that wealth screens not be used in the state’s foundation funding calculation.
- The court ordered further legislative action to remedy ongoing deficiencies and retained jurisdiction to monitor compliance.
- The court indicated certain funding adjustments were to be applied retroactively to July 1, 2001 (later disputed in post-decision proceedings).

## Legal Principles

- Article VI, Section 2 imposes a judicially enforceable obligation on the General Assembly to maintain a “thorough and efficient” statewide system of common schools.
- Compliance requires more than formal equality in a funding formula; the system must provide resources sufficient for districts to meet state educational standards.
- A base-cost calculation used as the foundation for statewide funding must be rationally tied to the actual costs incurred by districts that successfully meet performance requirements.
- Methodological choices that systematically understate the cost of adequacy—such as excluding districts based on wealth rather than educational criteria and selecting lower expenditure years—can render a funding scheme constitutionally deficient.
- In enforcing the constitutional mandate, a court may impose methodological constraints and require corrective action while leaving the detailed design of the funding system to the legislature, and may retain jurisdiction to ensure compliance.

## Conclusion

The Supreme Court of Ohio held that Ohio’s post-remand school-funding revisions still failed to provide a “thorough and efficient” system as required by Article VI, Section 2, invalidated core aspects of the base-cost methodology (including wealth screens), ordered further corrective legislation with specified constraints, and retained jurisdiction to oversee continued compliance.


DeRolph v. State, 93 Ohio St. 3d 309, 754 N.E.2d 1184 (Ohio 2001)