Leandro: The North Carolina Context

The Right to a Sound Basic Education

North Carolina’s efforts to provide a sound basic education for every child date back to the 1868 State Constitution requiring the General Assembly to provide “a general and uniform system of public schools, wherein tuition shall be free of charge to all of the children of the State.”

While several reforms have been made over the ensuing years, the state has struggled to fulfill its educational commitment for all its children, leading to the Leandro v. State case in 1994. The 1997 Supreme Court decision unanimously affirmed that the North Carolina constitution guarantees every child of the state “an opportunity to receive a sound basic education” that provides students with sufficient:

Mastery of English, mathematics, and physical science “to enable the student to function in a complex and rapidly changing society”;
Knowledge of geography, history, economics, and political systems to make informed choices within the democratic system; and
Academic and vocational skills to engage in and succeed in post-secondary education or vocational training.

Over subsequent years, court orders have required the state to:

Set a high bar for the achievement level that would demonstrate a sound basic education
Fund preschool programs for at-risk 4-year-olds
Support low-performing schools

State Efforts to Address the Leandro Requirements

North Carolina was recognized during the 1980s and 1990s as an example of how investments in teachers and early childhood support and strong standards could result in sharp increases in student performance and reductions to the achievement gap. However, post-Recession budget cuts and misguided policy priorities have reversed the gains made in previous decades.

Efforts to address Leandro have included:

Strengthening the Educator Workforce: The Teaching Fellows and Principal Fellows programs helped address the shortage of qualified teachers and principals, while small-scale programs such as the New Teacher Support Program and the Distinguished Leadership in Practice program provide support to beginning educators.
Preparing Pre-K Students for Success in School: Head Start, Smart Start, and NC Pre-K are high-quality programs, but funding has been restricted, leaving many at-risk children unserved.
Improving Curriculum and Teaching Practices: Math and reading standards have been regularly updated and strengthened, but lack of funding for professional development has hindered implementation.
Supporting the Improvement of Low-Performing Schools: The Department of Public Instruction once supported low-performing schools, but these efforts have been dismantled. Existing systems of support are inadequate.
Providing School Choice and Extended Learning Opportunities for Students: Cooperative Innovative High Schools and Career and College Promise have enabled high school students to obtain college credit, while career and technical education (CTE) programs provide many students with workplace skills and credentials.
Extensive Data Systems to Inform Decisions at All Levels: The state has high-quality data systems that facilitate evaluation and can be updated to track progress towards providing a sound basic education for all students.
Funding to Access Critical Needs: Resources have not been adequate to serve students with greater needs, such as providing support personnel and interventions that increase achievement.

Increased Challenges

Efforts to meet Leandro goals have been insufficient to meet Leandro requirements. The state now faces greater challenges than ever in meeting its constitutional responsibilities.

Updates to Standards and Assessments: The adoption of more rigorous standards – combined with a failure to provide the professional development necessary to implement those standards – have increased the challenges to prepare students to achieve proficiency.
Shifts in the Educator Workforce: Enrollment in teacher education programs declined by more than 50% between 2008-09 and 2015-16. Budget cuts have reduced the total number of teachers employed in North Carolina by 5% from 2009 to 2018. Further, North Carolina’s distribution of teachers is inequitable.
State Investments Not Keeping Pace with Education Needs: In the last two decades, school enrollment has grown by about 25% and the share of children with higher needs (economically-disadvantaged, English learners, etc.) has increased significantly. According to the most recent data, North Carolina’s per-pupil spending declined about 6% since 2009-10 and is the sixth-lowest in the nation.

Student Achievement Since the 1997 Leandro Decision

Achievement on North Carolina End-of-Grade Tests: There has been almost no progress since the current standards were set in 2013, with only about one-third of students in grades 3-8 reaching proficiency in both math and reading. Opportunity gaps for Black and Latinx students narrowed in the 1993 to 2005 period but have increased in recent years.
Achievement on the National Assessment of Educational Progress: NAEP results similarly show a lack of progress in improving achievement and in closing racial opportunity gaps.
Graduation Rates and Preparation for Postsecondary Education: Graduation rates have increased from 70% in 2008 to 86% in 2018, however, college completion rates show that few students are prepared for postsecondary education or the workforce.

North Carolina’s Current Education Goals

North Carolina’s achievement goals under ESSA are ambitious but would still leave more than one-third of students in grades 3-8 below proficient in reading and more than one-fourth below proficient in math.

Current Status of Leandro Compliance

Both Judge Manning’s final court order in 2015 and Judge Lee’s 2018 ruling concluded that North Carolina is failing to meet its constitutional obligation to provide every child with a sound basic education and that a plan of action is necessary to meet the state’s duties.

The requirements of the Leandro decision remain as relevant as ever, as today the state is further away from meeting its constitutional obligation to provide every child with the opportunity for a sound basic education than it was when the original Leandro decision was issued more than 20 years ago.