This suit illustrates the applicability of the adequacy theory to both low-wealth rural districts, as well as high-wealth, high-need urban systems.

The North Carolina Supreme Court ruled in July 1997 that the complaining school systems are entitled to a trial, and that the state constitution does guarantee all schoolchildren a basic, adequate level of educational opportunities. Significantly, the court also ruled that variations in spending that result from local add-ons would be permitted in the system so long as all districts could provide students with the constitutionally guaranteed minimum level of opportunities.

Events in Wyoming over the last decade and a half also have brought the issue of educational adequacy to the political and judicial forefront. In 1980, the Wyoming Supreme Court found that the state education funding system violated the state constitution's equity requirement, noting that "until the equality of financing is achieved, there is no practicable method of achieving the equality of quality" (Washakie v. Herschler, 606 P.2d 310, Wash. 1980). In its 1995 decision (Campbell v. State, 907 P.2d 1238, Wyo. 1995), the court ruled that the legislature's response to the 1980 decision was deficient and ordered the following:

The legislature must first design the best educational system by identifying the "proper" educational package each Wyoming student is entitled to have. … The cost of that educational package must then be determined and the legislature must then take the necessary action to fund that package. Because education is one of the state's most important functions, lack of financial resources will not be an acceptable reason for failure to provide the best education system. All other financial considerations must yield until education is funded.

Recall that the Kentucky court, for example, had provided the legislature with very broad guidelines as to what constituted the components of an adequate education. But it had left it to the legislature to design a school finance system that fit within those broad guidelines. The Wyoming court, by contrast, did not articulate such broad guidelines. Rather, it specifically directed the legislature to determine what is a "proper educational package" for all Wyoming students. The bite of its order, however, was that once the legislature identified that package, the state had the constitutional duty both to determine how much it would cost and to fully fund it. The court emphasized that the legislature's funding decisions could not be driven by politics or concerns about revenue availability, but must instead make judgments about actual educational goals, needs, and costs.

Significantly, the Wyoming court rejected the notion that local school districts could exercise their local taxing power to supplement the state provision of school finances. Indeed, the court noted that "historical analysis reveals local control is not a constitutionally recognized interest and cannot be the basis for disparity in equal educational opportunity." This approach, however, seems to be more of an exception than a rule in adequacy litigation. Indeed, most states and state courts addressing adequacy concerns have approached the issue more like



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