## Facts

- Parents, students, and school boards from several low-wealth North Carolina counties alleged the State’s school finance system denied students equal educational opportunity.
- Additional parents, students, and school boards from higher-wealth or urban districts intervened.
- Plaintiffs claimed state constitutional provisions imposed enforceable duties on the State to provide adequate educational opportunities statewide, regardless of local wealth differences.
- The trial court dismissed the complaint, reasoning the dispute was a nonjusticiable political question and that the Constitution did not guarantee the asserted level of educational quality.
- The North Carolina Court of Appeals largely affirmed the dismissal.
- The North Carolina Supreme Court granted discretionary review.

## Issues

1. Whether alleged failures to meet constitutional education duties present a justiciable controversy or a political question reserved to the General Assembly.
2. Whether the North Carolina Constitution guarantees each child a qualitative right to an adequate education.
3. Whether the Constitution requires equalization of inter-district school funding or educational opportunities among counties with differing fiscal capacity.

## Decision

- The North Carolina Supreme Court reversed in part and remanded for further proceedings.
- The court held education-adequacy claims under the state constitution are justiciable; courts may determine whether the State has complied with constitutional requirements.
- The court held every child in North Carolina has a fundamental constitutional right to the opportunity to receive a “sound basic education.”
- The court rejected a constitutional entitlement for counties or districts to equalized funding or complete equalization of inter-district opportunities.
- The court held the State bears the ultimate constitutional responsibility to ensure the opportunity for a sound basic education is available in every district.
- The case was remanded for fact-finding on whether, in practice, students in plaintiff districts were being denied that opportunity (including issues such as teacher quality, administration, and resources).

## Legal Principles

- Article I, Section 15 and Article IX, Section 2(1) together secure for each child a fundamental right to the opportunity for a “sound basic education.”
- A “sound basic education” includes the opportunity to acquire: (i) functional literacy and sufficient knowledge of fundamental mathematics and physical science; (ii) sufficient knowledge of geography, history, and basic economic and political systems for informed civic participation; and (iii) sufficient academic and vocational skills for postsecondary education or gainful employment.
- Courts have authority to interpret constitutional education guarantees and to decide whether legislative and executive actions satisfy them, even though education policy choices largely remain with the political branches.
- The Constitution permits local supplementation of school funding; resulting wealth-based differences are not unconstitutional unless they deny students the minimum opportunity for a sound basic education.
- The State’s constitutional education duty is affirmative and cannot be avoided by relying on local governments’ roles in funding and administering schools.

## Conclusion

The court recognized a judicially enforceable, child-centered right to the opportunity for a sound basic education under the North Carolina Constitution, rejected a standalone right to equalized inter-district funding, and remanded for trial to determine whether the State’s system, as implemented, was denying that minimum educational opportunity in the plaintiff districts.


Leandro v. State, 488 S.E.2d 249 (N.C. 1997)