Paynter v. State of New York, 100 N.Y.2d 434, 797 N.E.2d 1225 (N.Y. 2003).

In this action brought on behalf of students in the Rochester City School District claiming that the state’s policies and practices had resulted in high concentrations of minority population and poverty and poor student performance, the Court affirmed the grant of defendants’ motion to dismiss for failure to state a claim.  The Court noted that plaintiffs had not alleged that the deficiencies of which they complained had been caused by deficiencies in teaching, educational facilities or other “instrumentalities of learning,” and ruled that as long as the state provides sufficient educational resources, it satisfies its constitutional mandate even if student performance remains substandard.


Campaign for Fiscal Equity v. State of New York, 100 N.Y.2d 893, 801 N.E.2d 326, (N.Y. 2003).

The Court of Appeals ruled that the state’s public school financing system violated the education clause of the state constitution, as New York City public school children were not receiving the opportunity for a “sound basic education” (the standard set by the Court of Appeals in its 1982 decision, Bd. of Ed. Levittown Free Union Sch. Dist. v. Nyquist, 57 N.Y.2d 27, 48, 439 N.E.2d 359, 369, 453 N.Y.S.2d 643, 653 (1982)).  The Court defined“‘sound basic education’ as one which requires that ‘all students have the opportunity for a meaningful high school education, one which prepares them to function productively as civic participants.’”  The Court stated that “the funding level necessary to provide City students with the opportunity for a ‘sound and basic education’ is an ascertainable starting point” to fulfill the constitutional mandate, and further stated that “[o]nce the necessary funding level is determined, the question will be whether the inputs and outputs improve to a constitutionally acceptable level.”  The State has until July 30, 2004 to implement the necessary changes in the current system.


Campaign for Fiscal Equity v. State of New York, 86 N.Y.2d 307, 655 N.E.2d 661 (N.Y. 1995).

A sound basic education “should consist of the basic literacy, calculating, and verbal skills necessary to enable children to eventually function productively as civic participants capable of voting and serving on a jury.” “’Children are entitled to minimally adequate physical facilities and classrooms which provide enough light, space, heat, and air to permit children to learn. Children should have access to minimally adequate instrumentalities of learning such as desks, chairs, pencils, and reasonably current textbooks. Children are also entitled to minimally adequate teaching of reasonably up-to-date basic curricula such as reading, writing, mathematics, science, and social studies, by sufficient personnel adequately trained to teach those subject areas.’” 


Reform Educ. Fin. Inequities Today v. Cuomo, 86 N.Y.2d 279, 655 N.E.2d 647 (N.Y. 1995).

The Court of Appeals upheld the dismissal of plaintiffs’ complaint for failure to state a cause of action, finding that they had failed to show how “disparities have caused students in the poorer districts to receive less than a sound basic education, which is all that they are guaranteed by our Constitution.”  The Court ruled that the education clause in the state constitution did not require all school facilities to be substantially equal, and further ruled that a gross disparity in funding, alone, was insufficient to demonstrate the absence of a sound basic education.


Bd. of Educ. Levittown Free Union Sch. Dist. v. Nyquist, 57 N.Y.2d 27, 439 N.E.2d 359 (N.Y. 1982).

The Court of Appeals acknowledged the existence of "significant inequalities in the availability of financial support for local school districts, ranging from minor discrepancies to major differences, resulting in significant unevenness in the educational opportunities offered," 57 N.Y.2d at 38, but determined that the constitutional requirement was being met, since the state was providing a “sound basic education” in its public schools.  Id. at 48.  “The circumstance that public education is unquestionably high on the list of priorities of governmental concern and responsibility, involving the expenditures of enormous sums of State and local revenue, enlisting the most active attention of our citizenry and of our Legislature, and manifested by express articulation in our State Constitution, does not automatically entitle it to classification as a "fundamental constitutional right" triggering a higher standard of judicial review for purposes of equal protection analysis.”  Id. at 43.