Leandro v. State
488 S.E.2d 249 (N.C. 1997)
Background
In 1994, a lawsuit was filed against the State of North Carolina by parents, children and school districts in five low-wealth rural counties (Hoke, Halifax, Robeson, Vance and Cumberland). The Plaintiffs (including the Leandro family) argued that, despite higher than average tax rates, schools in these counties ended up with lower than average tax revenues. This meant that these school districts did not have enough money to provide an equal education for their children. For example, they could not compete with wealthier school districts in terms of teacher pay, special services or educational materials.
The heart of the Plaintiff’s case was the argument that the quality of child’s education ought not be dependent upon the wealth of the family and community into which that child was born. It costs more to properly educate disadvantaged children, but the State had not done enough to equalize school funding across NC. The Plaintiff’s proposed solution was a higher level of stable funding for these low-wealth counties.
A number of urban school districts were allowed to intervene in the Leandro lawsuit. They raised a second and equally important issue. They claimed that their schools were burdened with large numbers and heavy concentrations of disadvantaged and more-costly-to-educate students. Therefore, they argued that the State Constitution requires North Carolina to provide schools anywhere in the state with “adequate” resources to fully educate disadvantaged – that is, poor, special education and Limited English Proficient — students.
Relevancy to School Discipline Cases
The North Carolina Supreme Court held that all children residing in North Carolina have a fundamental state constitutional right to the “opportunity to receive a sound basic education.” In a later case, King v. Beaufort County Bd. of Educ., 364 N.C. 368, 704 S.E.2d 259 (2010), the NC Supreme Court relied on this standard to find that students who are suspended have a right to alternative education unless the district can articulate a substantial reason why it cannot provide alternative education.
Held
A unanimous Court stated that neither school districts nor counties have any constitutional right to equal funding. But the Court went on to rule that children – indeed, all children residing in North Carolina – have a fundamental state constitutional right to the “opportunity to receive a sound basic education.”
Of equal significance, the Supreme Court ruled that the State of North Carolina, not local school districts, has the ultimate constitutional obligation to actively safeguard and successfully deliver every child’s Leandro right. No exceptions. No excuses.
The Court defined a sound basic education as that which provides children and youth with all the opportunities necessary to become an adult possessing:
- Sufficient ability to read, write and speak the English language and a sufficient knowledge of fundamental mathematics and physical science to enable the student to function in a complex and rapidly changing society;
- Sufficient fundamental knowledge of geography, history, and basic economic and political systems to enable the student to make informed choices with regard to issues that affect the student personally or affect the student’s community, state, and nation;
- Sufficient academic and vocational skills to enable the student to successfully engage in post-secondary education or vocational training; and
- Sufficient academic and vocational skills to enable the student to compete on an equal basis with others in further formal education or gainful employment in contemporary society.