86 N.Y.2d 307 (1995)

The Education Article of the New York State Constitution requires the State to provide all children with the opportunity for a sound basic education, consisting of fundamental literacy, calculation, and verbal skills, and a claim that the current funding system fails to provide this is sufficient to survive a motion to dismiss.

Summary

Campaign for Fiscal Equity, Inc. (CFE) sued the State of New York, alleging the public school financing system was unconstitutional. CFE claimed violations of the Education Article, Equal Protection Clauses, and Title VI of the Civil Rights Act. The Court of Appeals held that the nonschool board plaintiffs stated a valid claim under the Education Article, requiring the State to offer all children the opportunity for a sound basic education. The Court found the complaint sufficiently alleged that New York City school children were not receiving this opportunity. The Court also found a valid cause of action had been pleaded under Title VI’s implementing regulations.

Facts

Plaintiffs, including CFE, school districts, individual students, and parents, challenged New York State’s public school financing system. They alleged the system violated the Education Article, Equal Protection Clauses, the Antidiscrimination Clause of the State Constitution, and Title VI of the Civil Rights Act. The State’s financing scheme resulted in inadequate educational opportunities for students in New York City, particularly concerning literacy, calculation, and verbal skills.

Procedural History

The State moved to dismiss the claims. Supreme Court dismissed claims by school districts for lack of capacity to sue, dismissed equal protection and Title VI claims for failure to state a cause of action, but upheld claims under the Education Article, Antidiscrimination Clause, and Title VI regulations. The Appellate Division reversed, dismissing all claims. The Court of Appeals modified, reinstating the Education Article claim and the Title VI regulations claim for nonschool board plaintiffs.

Issue(s)

1. Whether the State’s school financing scheme violates the Education Article of the New York Constitution by failing to provide public school students in New York City an opportunity to obtain a sound basic education.
2. Whether the State’s school financing scheme violates the Equal Protection Clauses of the State and Federal Constitutions.
3. Whether the State’s public education financing system violates Title VI of the Civil Rights Act and its implementing regulations.

Holding

1. Yes, because the complaint alleges and specifies gross educational inadequacies that, if proven, could support a conclusion that the State’s public school financing system effectively fails to provide for a minimally adequate educational opportunity.
2. No, because the rational basis test applies, and the financing scheme is rationally based on the State’s legitimate interest in preserving local control of education.
3. Yes, as to Title VI’s implementing regulations only, because proof of discriminatory effect suffices to establish liability under the regulations, and plaintiffs statistically support their allegations of disparate impact on minority students. Intentional discrimination must be shown to succeed on a Title VI claim.

Court’s Reasoning

The Court reasoned that the Education Article requires the State to offer all children the opportunity for a sound basic education, consisting of basic literacy, calculating, and verbal skills necessary for civic participation. The Court distinguished this case from Board of Educ., Levittown Union Free School Dist. v Nyquist, 57 N.Y.2d 27 (1982), noting that the Levittown plaintiffs did not claim a deprivation of minimal acceptable facilities and services. Here, the plaintiffs advance the very claim that minimally acceptable services and facilities are not being provided in the plaintiff’s school districts.

The Court emphasized that Levittown left room for a conclusion that a system failing to provide a sound basic education would violate the Education Article. The Court held the plaintiffs stated a valid cause of action under the Education Article because they supported their allegations with fact-based claims of inadequacies in physical facilities, curricula, numbers of qualified teachers, availability of textbooks, library books, etc.

Regarding the Equal Protection claims, the Court applied the rational basis test, following Levittown and San Antonio School Dist. v Rodriguez, 411 U.S. 1 (1973). The Court rejected the argument for heightened scrutiny based on disparate impact, noting the lack of alleged discriminatory intent.

As for Title VI, the Court found a cause of action stated under the implementing regulations, which incorporate a disparate impact standard. Proof of discriminatory effect suffices, and the complaint challenges the State’s allocation of education aid, alleging a disparate impact on racial and ethnic minorities in New York City schools.