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Rose v. Council for Better Education (1989) was a major school-funding case based on adequacy arguments inspired by the language of state constitutions. In Rose, the Supreme Court of Kentucky interpreted the commonwealth's constitutional provision as mandating its general assembly to “provide an efficient system of common schools throughout the state.” The court held that the general assembly fell far short of its duty by failing to enact laws to provide an “efficient” education. In a sweeping opinion, Rose struck down not just the commonwealth's education finance system, but the entire educational bureaucracy in Kentucky. In other words, the court essentially invalidated the entire system and ordered the legislature to start over. The result, the Kentucky Educational Reform Act, has been a sweeping overhaul of ...

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