In 1994, North Carolinians from five rural counties sued the state government, alleging that the system then used to finance public education was unfair to students in low-income communities and thus unconstitutional.
The lead plantiff, then-student Robb Leandro, became the namesake for the long-running litigation, the Leandro case. It’s been through trial courts and appellate courts multiple times. Most recently, Democrats, then constituting a majority on the North Carolina Supreme Court, seemed poised to trigger a constitutional crisis — by trying to compel funding for a “remedial” program concocted by an out-of-state progressive group. But then, in 2022, Republican justices won a court majority.
Even before voters put an end to this latest gambit — the unconstitutional attempt by the state judiciary to exercise legislative power — by electing originalist judges, the Leandro case had undergone a fundamental transformation. It began life in 1994 as a claim that North Carolina’s lower-income school districts were grossly underfunded when compared to urban districts. Within a few short years, however, the central claim had changed: virtually all districts in the state, not just poor or rural ones, were supposedly underfunded.
In other words, the case was no longer about equity. It was about adequacy.
Why? Well, for starters, it’s important to understand that the Leandro case was part of a larger national left-wing strategy to use litigation as a lever to boost funding for public schools. The strategy, initiated in the 1970s, made more sense in states where local property taxes were the primary source of education revenues. Such a practice really can produce large disparities.
In North Carolina, however, we got rid of that financial model nearly a century ago. In 1994, our schools were primarily funded at the state level, by income and sales taxes. Since then, the local share has fallen further, to about a quarter of total spending. In Texas, by contrast, local funding makes up 56%. The national average is 46%.
As the school-reform group BEST NC documents in its latest Facts & Figures booklet, a combination of state and federal action has eliminated whatever funding disparities may once have existed among North Carolina districts. Consider household income. Among the quartile of schools with the highest rates of student poverty, total expenditures last year averaged $14,332 per pupil. Among the schools with the lowest poverty rates, total expenditures were $11,359 per pupil.
As for location, rural and non-rural schools spent nearly the same amounts per pupil, $12,029 and $12,212 respectively.
Although North Carolina was ahead of the curve in tweaking its finance system to redistribute education dollars, many other states have been doing the same thing. Federal programs also play a larger role than before in directing funds to low-income students and those with special needs.
As research director Adam Tyner put it in a recent paper for the Thomas B. Fordham Institute, school funding in the United States “is now generally progressive, meaning that students from poor families generally attend better-funded schools than students from wealthier families in the same state.”
By reporting these facts, I don’t mean to suggest that debates about education funding are settled — or, indeed, that they can ever be settled.
Some think public schools ought to be funded at much higher levels, that they need more money for supplies and technology, and that dramatically increasing average salaries would boost student learning by attracting and retaining higher-quality teachers. Others argue that schools should spent their existing dollars more wisely, that empowering parents to make choices among competing schools will increase their productivity, and that pay raises should be focused on early-career teachers and those who are demonstrably more effective at teaching students.
By all means, let’s talk about these and related issues. To that end, let’s stop pretending that funding disparities based on income or geography are significant obstacles to student success. They’re not.
And let’s finally put an end to the Leandro case, which attempted to substitute litigation for legislation. That was never a good idea.
John Hood is a John Locke Foundation board member. His latest books, Mountain Folk and Forest Folk, combine epic fantasy with early American history.