## Facts

- Public school students in Canton, Connecticut, and their parents challenged the constitutionality of Connecticut’s elementary and secondary school finance system.
- At the time of trial, public education funding came primarily from local property taxes, supplemented by a flat per-pupil state grant and minor federal funds.
- Approximately 70% of funding was local, 20–25% was state (flat per-pupil), and about 5% was federal.
- Towns’ ability to fund schools depended heavily on taxable property per pupil, producing wide disparities in taxable wealth among towns.
- Property-poor towns often faced higher tax rates but raised less revenue than property-rich towns, limiting per-pupil spending.
- The trial court found a direct relationship between per-pupil expenditures and educational program breadth and quality, and concluded that wealth-based disparities affected educational opportunity.
- The trial court declared the finance system unconstitutional under the Connecticut Constitution and ordered equitable relief aimed at transitioning to a constitutional system while retaining jurisdiction.
- State officials appealed; plaintiffs cross-appealed on aspects of relief. The appeals were consolidated.

## Issues

1. Whether the Connecticut Constitution makes the right to public education a fundamental right requiring strict scrutiny of laws that materially affect access to education.
2. Whether a school finance system primarily driven by local property wealth, with a largely non-equalizing flat state grant, violates state constitutional equal protection/equal rights guarantees and the constitutional command to provide free public elementary and secondary schools.
3. Whether courts or the legislature have primary responsibility to design and implement a constitutional education finance system after a judicial finding of unconstitutionality.

## Decision

- The Connecticut Supreme Court held that the right to education under the Connecticut Constitution is fundamental and that intrusions on that right are subject to strict scrutiny.
- The Court held the existing school finance system unconstitutional because it produced substantial, wealth-based disparities in educational opportunity among towns.
- The Court agreed that legitimate goals such as local control did not justify large disparities tied to local property wealth.
- The Court held that creating a constitutional education finance system is primarily a legislative task, not a judicial one.
- The Court affirmed the trial court’s core constitutional ruling and remanded for further proceedings consistent with legislative development of a replacement system, while approving continued trial court jurisdiction to oversee transition.

## Legal Principles

- The Connecticut Constitution’s education provision, read with state equality guarantees, protects education as a fundamental right.
- When a fundamental right to education is materially affected, the state must satisfy strict scrutiny; wealth-based disparities require compelling justification and close fit.
- A funding system that materially ties educational opportunities to local taxable property wealth, without meaningful state equalization, violates state equal protection/equal rights principles.
- Courts may declare a finance system unconstitutional and oversee compliance, but the design of a replacement funding structure is entrusted chiefly to the legislature.

## Conclusion

Connecticut recognized public education as a fundamental state constitutional right and invalidated a property-wealth-driven funding structure that generated major disparities in educational opportunity, while directing that the legislature craft the remedial finance system under judicial oversight limited to ensuring constitutional compliance.


Horton v. Meskill, 376 A.2d 359 (Conn. 1977)