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Leandro vs. the State of North Carolina
Leandro has a long, complicated history in North Carolina courts. Superior Court Judge Manning issued four Memoranda of Decision; the North Carolina Supreme Court also issued a decision.
Originally filed in January 1995, the Leandro case centers on three questions:
- Is there a baseline level of education to which all children in North Carolina are constitutionally entitled, and if so, what is it?
- Who is responsible for providing this baseline level of education? and
- Upon answering the former two questions, what are the parameters that the constitutionally responsible party must respect in providing the baseline level of education?
In 1997, the Supreme Court found that every child in North Carolina is constitutionally entitled to “a sound, basic education,” which is defined as 1) sufficient ability to read, write, and speak English, and practice mathematics and the physical sciences to allow the student to operate in a complex and rapidly changing society; 2) sufficient knowledge of geography, history, economics and politics to enable the student to competently participate in the community and nation; 3) sufficient academic and vocational skills to enable the student to successfully engage in post-secondary education or vocational training; and 4) sufficient academic and vocational skills to enable the student to compete on an equal basis with others in further formal education and gainful employment in contemporary society. The Supreme Court remanded the case and instructed the Superior Court to rule against the State contingent on evidence “to the effect that defendants in this case are denying children of the state a sound, basic education.”
At the Superior Court level, all parties agreed that End-of-Grade (EOG) and End-of-Course (EOC) testing was an appropriate measure to determine whether the Leandro standards were being met. The State argued, however, that Level II (below grade level) was adequate, while the individual school districts, or local education agencies (LEAs), argued that Level III (grade level) should be used as the baseline standard. The Superior Court found the LEAs’ argument more compelling. Statewide EOC and EOG clearly illustrated that Hoke County scores, along with many others, have consistently been “terrible.” This trend continued through the 2000-2001 school year. Consequently, Leandro established that the education being provided to these students was in violation of their right to a sound, basic education.
From then, the argument centered on the issues of funding and culpability. “The critical questions that the Court wanted to focus on were: Whether or not the at-risk children were failing to obtain a sound basic education because of (A) a lack of sufficient funding for educational programs (state culpability); (B) a lack of effective leadership implementing effective educational programs for at-risk children (LEA culpability); or (C) a combination of both (mutual culpability)?” In its verdict, the Superior Court found first that the provision of a sound, basic education is incumbent on the state because “the North Carolina Constitution clearly provides that it is the obligation of the State to provide each and every child with the equal opportunity to obtain a sound basic education. That obligation includes not only funding, but providing assistance to the LEAs who are not carrying out their duties in regard to the sound basic education.”
The Court based this conclusion on the fact that the LEAs are merely constituent branches of the State, created for the State’s convenience in administering its constitutional obligation of a sound, basic education to every child. Consequently, when an LEA fails to meet that standard, responsibility devolves to the State. Upon these findings, the Superior Court, “in accordance with Leandro, Ordered the State, not the LEAs, to fix the deficiencies that exist with at-risk children.”
In issuing this order, the Superior Court delved extensively into the criteria necessary for a child to receive a sound, basic education. These criteria are properly viewed as the parameters within which the State of North Carolina must act to remedy the constitutional complaints of its school children.
- Each school must have a good principal that is an effective, energetic, motivated leader. An integral facet of being a "good principal" is engaging in regular, high-quality professional development.
- Each classroom must have a good teacher who is competent, certified, effective and energetic. Competent teachers are fully equipped to assess their students accurately and then modify the curriculum to meet each child's special needs. The State must ensure that all students are taught by teachers working within their field of expertise. Further, staff development and on-going training for teachers is essential and necessary.
- No single educational method or program is necessary. There are many efficient ways to teach, provided that they all cover the Standard Course of Study in a focused manner.
- A safe and orderly environment in the School is essential in order for students to learn.
- High expectations of teachers and students are essential.
These criteria support the findings that:
- For at-risk children to have an equal opportunity for a sound, basic education, the State should provide quality pre-kindergarten programs for at-risk children.
- Economically disadvantaged children need opportunities and services over and above those provided to the general student population in order to put them in a position to obtain an equal opportunity to receive a sound basic education. These additional opportunities may include extra time on task, lower class sizes, early childhood education, individual tutoring, early intervention, or supplementary instruction and materials.
- Competent, well-trained teachers who are kept abreast of their subject matter through professional development are essential to dealing with the needs of at-risk children.
Leandro was a groundbreaking decision in North Carolina and the nation. By mandating the State to refocus its education system onto the idea that all children can and should learn, the Court recognized the critical role that teacher quality plays in a proper education. This is the first step in revising a lackluster education system into one that respects the rights of every child to learn and is willing to take whatever action is necessary to ensure that they do.