The Connecticut Supreme Court recently issued a decision in the case of Connecticut Coalition for Justice in Education Funding v. Rell, a ruling that could have significant implications in the way the State funds public education. In Connecticut Coalition for Justice, a plurality of the Supreme Court ruled that the Connecticut Constitution guarantees the State’s students not just a public education, but one that provides public school students with “educational standards and resources suitable to participate in democratic institutions, and to prepare them to attain productive employment and otherwise to contribute to the [S]tate’s economy, or to progress on to higher education.”
The plaintiffs in the case are parents of children who attend public schools in Bridgeport, Danbury, Windham, Hartford, New Haven, East Hartford, New London, Plainfield and New Britain. The plaintiffs asserted that the State had failed to provide their children with a suitable educational opportunity because of “inadequate and unequal [educational] inputs,” which, the plaintiffs alleged, “are essential components of a suitable educational opportunity.” Specifically, the plaintiffs claimed that the State had failed to provide for sufficient educational resources including, among other things, appropriate class sizes; a rigorous curriculum with a wide breadth of courses; and a school environment that is healthy, safe, well maintained and conducive to learning.
The plaintiffs further alleged that the State’s failure to provide them with a suitable and substantially equal educational opportunity harmed them by rendering them “unable to take full advantage of the country’s democratic processes and institutions, risking political and social marginalization.” Moreover, the plaintiffs asserted that they were being educated in a system that “sets them up for economic, social, and intellectual failure.” The defendants in the case — various State officials and members of the State Board of Education — responded that the Connecticut Constitution does not confer a right to “suitable” educational opportunities, and does not “guarantee equality or parity of educational achievement or results.”
In a reversal of the judgment of the trial court in this matter, a plurality of the Connecticut Supreme Court ruled for the plaintiffs, holding that Article Eighth, § 1, of the Connecticut Constitution does in fact guarantee Connecticut’s public school students “the right to a particular minimum quality of education, namely, suitable educational opportunities.” The plurality ruled that a constitutionally adequate education will “leave Connecticut’s students prepared to progress to institutions of higher education, or to attain productive employment and otherwise contribute to the [S]tate’s economy.” The plurality went on to suggest that the following are some of the “essential” components to a constitutionally adequate education: “(1) minimally adequate physical facilities and classrooms [that] provide enough light, space, heat, and air to allow children to learn; (2) minimally adequate instrumentalities of learning such as desks, chairs, pencils, and reasonably current textbooks; (3) minimally adequate teaching of reasonably up-to-date basic curricula such as reading, writing, mathematics, science, and social studies; and (4) sufficient personnel adequately trained to teach those subject areas.” The Supreme Court remanded the case to the trial court, which will be required to determine the factual issue of whether the State’s educational resources and standards have in fact provided the public school students involved in the case with constitutionally suitable educational opportunities.
The case potentially has far-reaching consequences for education in Connecticut because the ruling establishes that the Connecticut Constitution contains a significant qualitative component with regard to the provision of education to Connecticut’s students. In its ruling, the plurality drew on statistical evidence to show that the availability and quality of certain inputs to education “vary significantly in schools across the [S]tate.” The plurality cited, for example, the fact that in a certain elementary school in the State only 50% of kindergarten students attended preschool, nursery school or Head Start, as compared to 76% of students statewide. Similarly, at this same school, none of the computers were high or moderate powered, compared to a statewide average of 76%. If a trial court were to determine that these facts give rise to constitutionally unsuitable educational opportunities for students, fundamental changes to the State’s system of educational funding could be necessary. The Connecticut Supreme Court’s decision on this issue is available here: http://www.jud.ct.gov/external/supapp/archiveAROsup10.htm.