Tuesday, July 1, 2025

Morse, Jane Fowler. (2007). A Level Playing Field: School Finance in the Northeast. Reviewed by Craig L. Esposito, University of Connecticut

Morse, Jane Fowler. (2007). A Level Playing Field: School Finance in the Northeast. Albany, NY. State University of New York Press.

Pp. xv + 349     $30     ISBN ISBN 0-7914-6932-8

Reviewed by Craig L. Esposito
University of Connecticut

August 12, 2008

This broad-ranging and ambitious volume addresses two of the most important, and seemingly insoluble, questions in education: how do we provide all children with an equal opportunity for an adequate education, and why do our best efforts to do so keep coming up short? Jane Fowler Morse makes an impassioned plea for better funding of our schools, details three case histories from which citizens, researchers and policymakers interested in school finance reform can learn lessons, and provides an impressive and useful set of citations, references, and law cases. She also examines how racism, classism, and poverty intersect to make adequate school financing more difficult. This book would be an excellent resource for anyone who is interested in a broad outline of school finance litigation history, the narrow, magnified, and granular view of the three case histories, and a look at some of the root causes of educational disparities.

The book begins with a brief history of the development of public education in the United States and then moves into a general review of early school finance litigation on a national level. She describes the legal reasoning that prevailed in those early state and federal cases, and how the legal concepts for school finance litigation have evolved, shifted, and changed over the years. She then provides detailed case studies of three efforts to reform school finance that used different strategies-- New York State, Vermont, and Ontario, Canada—to show how difficult, protracted, contradictory, unpredictable and unsatisfactory the results of school reform can be, regardless of the strategy employed.

In New York, judicially-originated reforms took over thirty years to be even partially implemented; in Vermont, quickly enacted reforms almost as quickly began to erode; and in Ontario, centralization and cost efficiencies driven by a conservative agenda to equalize education expenditures instead resulted in a decrease in educational funding. The author amply highlights how, in school finance reform, ‘the more things change, the more they remain the same’ by describing the many forces undermining change: winning in the courts often means little change in the disparity between rich and poor districts, as wealthy districts increase their spending to maintain their superiority over poorer districts; spending is reduced downwards to provide “equality” that hurts everyone; states with weak education clauses often move more quickly and decisively than states with strong education clauses; legislatures are slow to respond when directed to do so by courts; the courts are reluctant to usurp ‘separation of powers’ and the legislatures’ prerogatives even when disparities are glaring and blatant; the desire for local control versus state funding; and even when reforms are implemented, they quickly erode or become outdated (Thompson & Crampton, 2002).

It is evident that Dr. Morse embraces the concept of adequacy, which takes into account not only how much is spent on students, but just as importantly considers outcomes as well (Duncombe & Lukemeyer, 2002). The book details how adequacy is the outgrowth of a 50 year nation-wide effort to reform schools and school finance in the courts to make the distribution of public funds and public opportunities for education more equitable. Starting with the Supreme Court’s ruling in Brown v. Board of Education of Topeka (1954) that segregation violated the equal protection clause of the Fourteenth Amendment, and violated “a right (to education) which must be available to all on equal terms.” (*494), the author describes the three periods or “waves” of school finance reform (Heise, 1995). Each wave corresponds to a different legal theory regarding the funding of public education in the United States. The first wave relied on the federal constitution’s equal protection clause, as in Brown or in Serrano v. Priest (1971). The US Supreme Court brought this period to an end in San Antonio Independent School District v. Rodriguez (1973), ruling that under the US Constitution’s 10th Amendment, education was a power reserved to the states, and not subject to federal equal protection interpretations. Proponents for financing reform then turned to the states and their constitutions for redress.

This second wave began after Rodriguez and focused on equity of funding and state constitution equal protection and education clauses. It addressed the discrepancy in per pupil spending in school districts due to the reliance on local revenues for funding. Poor districts could not raise funds equivalent to those raised by their wealthier counterparts, and state courts often agreed that the states must do more to equalize the resources provided to students throughout the state.

The third wave began in 1989, with equity concerns evolving into a focus on adequacy, typified by the Kentucky case, Rose v. Council for Better Education (1989). The book details the seven minimum goals the Kentucky Supreme Court considered necessary for an adequate education. Adequacy presumed that horizontal equity (i.e., treating everyone the same) was insufficient, because, depending on their circumstances, some students required more to overcome the obstacles to an adequate education. Equal was not necessarily adequate, and while equity concerns itself with whether the financing is equivalent for all students, adequacy asks if the opportunities for a minimally acceptable education (as defined by the state) are equally and fairly distributed. While this standard might seem quite clear and straightforward, the author documents how different states can differ radically in their interpretation and definiton of adequacy and how it is to be achieved.

The second half of the book takes a broader view of school finance and looks at how classism, racism and poverty are responsible for much of the underlying disparities and inequalities, how these affect school children, and how efforts at school finance reform must explicitly address these areas to be successful. The author makes a strong case for a systems approach, arguing that education is part of an overall system, and one must address the issues of wealth inequities, residential segregation, social welfare programs, and other public policies which actually determine much of the context in which education does, or does not, take place. To use a medical analogy, it is ultimately better to treat the cause of a disease, rather than treat the symptoms.

In keeping with her premise that other systemic forces beyond the educational system are at work, e.g., racism, poverty, classism, the author details how the majority of court victories in finance cases involve poor white students, while minority districts win a far smaller percentage of their cases; how lead contamination affects the poor far more than the wealthy; that social services for the poor and minorities have declined; the growth of prisons and the incarceration rate in the United States to warehouse our educational and social failures; and the racial double standard of the current standards movement. Yet despite the slow progress of finance reform and all of the obstacles arrayed against its success, the author’s tone is not pessimistic. In fact, she seems energized by the challenges confronting society in its struggle for better education for everyone. Hopefully, readers of this book will also feel re-energized and rededicated to pursuing social justice and improved educational outcomes.

References

Brown v.Board of Education of Topeka, No. 1, 1954 U.S. Lexis 2094 (U.S. May 17, 1954).

Duncombe, W., & Lukemeyer, A. (2002). Estimating the Cost of Educational Adequacy: A Comparison of Approaches. Syracuse, NY: Center for Policy Research.

Heise, M. (1995). The Effect of Constitutional Litigation on Education Finance: More Preliminary Analyses and Modeling, Journal of Education Finance, 21, 195-216.

Rose v. Council for Better Education, Inc. No. 88-SC-804-TG, 1989 Ky. LEXIS 55 (Ky. June 8, 1989).

San Antonio Independent School District v. Rodriguez, 411 U.S. 1, 56 (1973).

Serrano v Priest, No. 29820, 1971 Cal. Lexis 273, (Cal August 30, 1971).

Thompson, D. C., & Crampton, F. E. (2002). The Impact of School Finance Litigation: A Long View. Journal of Education Finance, 27, 783-805.

About the Reviewer

Craig L. Esposito is a Ph.D. student in Educational Policy and Leadership at the University of Connecticut, Neag School of Education. His interests include school finance, school choice, and higher education funding.

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