The Leandro Case, a missed opportunity for NC education
- Virgil L. Smith, Carolina Commentary

- 2 days ago
- 3 min read
The Leandro v. State decision has long stood as a constitutional benchmark affirming that every child in North Carolina is entitled to a “sound basic education.” The recent action by the North Carolina Supreme Court declining to compel the legislature to fund the remedies tied to that obligation underscores a persistent institutional tension—one that sits at the intersection of judicial interpretation and legislative authority.
Supporters of the Court’s position correctly note that the judiciary does not wield the power of the purse. Appropriations are, by design, the responsibility of the legislative branch. That argument has merit. However, it omits a critical point: had the legislature consistently met its constitutional obligation, judicial intervention would never have been necessary. The courts did not initiate this conflict—they responded to it.
The data surrounding North Carolina’s education system reinforces this reality. While the state has made measurable progress in outcomes, it continues to lag significantly in investment. North Carolina currently spends approximately $12,000 per student, which is roughly $5,600 below the national average, placing it near the bottom nationally (around 50th) in per-pupil funding. (North Carolina Association of Educators) Among southern states, North Carolina also trails the regional average by nearly 9 percent, falling behind neighbors such as South Carolina and Alabama. (NC Newsline)

Even more concerning, when measured by effort—how much of its economic capacity the state devotes to education—North Carolina ranks last (51st) in the nation. (North Carolina Association of Educators) This is not merely a budgetary issue; it is a reflection of policy priorities.
At the same time, the state points to improving outcomes.
North Carolina’s high school graduation rate has reached a historic high of approximately 87.7 percent, an increase from 69 percent in 2006. (NC DPI) However, these gains mask persistent inequities. Graduation rates for economically disadvantaged students remain significantly lower—around 83 percent compared to 91 percent for their peers—highlighting systemic disparities tied directly to resource allocation. (MyFutureNC)
The transition from high school to higher education also reveals structural challenges.
While more than half of graduates take at least one college-level course, only about 36 percent leave high school with actual college credit, and overall college completion rates in the state hover around 49–50 percent. (NC DPI) These figures suggest that access to postsecondary opportunity remains uneven and incomplete.
This disconnect—between relatively improving outcomes and persistently low investment—creates a fragile foundation for the state’s future. Lawmakers frequently emphasize education as a cornerstone for economic development, particularly in attracting industries that offer high wages, strong benefits, and long-term career pathways. Yet those ambitions are undermined when the state ranks near the bottom nationally in funding and effort.
The consequences are especially pronounced in rural and underserved urban communities. Families without access to private education or supplemental resources depend entirely on public systems that are, by comparative standards, underfunded. At the same time, North Carolina faces intensifying competition for qualified teachers and administrators. Without sustained investment in salaries, training, and classroom resources, the state risks losing talent to neighboring states that are making stronger financial commitments.
In regional context, North Carolina’s standing is paradoxical. It is a top 10 state in population and economic output, yet remains in the bottom tier nationally in education funding, even as some southern peers invest more per student. (EdNC) This imbalance between capacity and commitment underscores the core issue at the heart of the Leandro case.
The refusal to fully fund the constitutional standard is not a neutral act—it is a policy choice with long-term implications. Education deficits compound over time, affecting workforce readiness, economic mobility, and community stability. The data already shows disparities by income, geography, and opportunity; without corrective action, those gaps will widen.
Ultimately, this issue returns to a fundamental principle of governance. Legislators swear an oath not only to represent their constituents, but to uphold the state constitution. That responsibility is not optional, nor is it situational. When constitutional obligations—particularly those tied to the education of children—are deferred, it is more than a political failure; it is a breach of public trust.
The bottom line is clear: North Carolina cannot simultaneously aspire to economic leadership while underinvesting in the very system that produces its future workforce. The longer the state delays in meeting its constitutional duty, the more profound—and more generational—the consequences will be.
The bottom line is clear: sustainable economic growth, social stability, and equitable opportunity all depend on a fully realized commitment to education. The longer the state delays in meeting its constitutional duty, the more profound—and more costly—the consequences will become.
Virgil L. Smith formerly served as president and publisher of the Asheville Citizen-Times and Vice President for Human Resources for the Gannett Company. He is the principal for the Smith Edwards Group and the author of "The Keys to Effective Leadership.” He is the founder and a writer for Carolina Commentary.




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