Equality, Adequacy, and Education for Citizenship

Author(s): Debra Satz

Source: Ethics , Vol. 117, No. 4, Symposium on Education and Equality (July 2007), pp. 623-
648
Published by: The University of Chicago Press
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Equality, Adequacy, and Education for
Citizenship*

Debra Satz

I. INTRODUCTION
There are significant inequalities in the lives of America’s children,
including inequalities in the education that these children receive.
These educational inequalities include not only disparities in funding
per pupil but also in class size, teacher qualification, and resources
such as books, labs, libraries, computers, and curriculum, as well as
the physical condition of the school and the safety of students within
it. While not all schools attended by poor children are bad schools,
and not all schools attended by well-off children are good schools,
there are clear patterns. Poor children are more likely to attend
crowded and poorly equipped schools with less qualified teachers than
the children of more affluent families.1 They are less likely to have
computers, books, and advanced placement academic courses. To give
one example of the differences in school resources, the wealthiest
districts in New York spent more than $25,000 per pupil at the same

* An earlier version of this article was presented at a conference on “The Theory

and Practice of Equality” at the Harvard University Kennedy School of Government, the
Princeton Center for Human Values, the Berkeley Workshop in Law, Philosophy and
Political Theory, the Stanford Political Theory Seminar, and a Massachusetts Institute
of Technology conference on education and inequality. I am grateful to the audiences
for valuable discussion and to Stefan Gosepath, Sam Scheffler, and Harry Brighouse,
who served as commentators on separate occasions. Thanks also to Elizabeth Anderson,
Larry Blum, Michael Bratman, Eamonn Callan, Joshua Cohen, Barbara Fried, Elizabeth
Hansot, David Hills, Judith Lichtenberg, Eleni Manis, Adam Swift, Allen Wood, John
Ferejohn, two anonymous reviewers at Ethics, and especially Rob Reich for comments on
the article and for discussing the issues with me. Thanks to Collin Anthony for research
assistance.
1. See Jonathan Kozol, Savage Inequalities: Children in America’s Schools (New York:
Harper Perennial, 1991), and The Shame of the Nation: The Restoration of Apartheid in America
(New York: Crown, 2005) for documentation of these disparities.

Ethics 117 ( July 2007): 623–648

䉷 2007 by The University of Chicago. All rights reserved. 0014-1704/2007/11704-
0001$10.00

623

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624 Ethics July 2007

time that the poorest district in Texas spent only about $1,200 per
pupil.2
Poor children in high poverty schools are also less likely to complete
high school than middle-class children in better funded middle-class
schools; less likely if they do to attend a four-year college; and very
unlikely to attend an elite, highly selective college. At elite colleges,
those at the bottom 28 percent of the socioeconomic scale make up
only 3 percent of the student population.3
The relationship between the disparities in educational resources
and these unequal educational outcomes is complex, since differential
outcomes are likely to be (at least partly) explained by factors outside
of schools, including differences in individual endowments and family
circumstances.4 Nevertheless, our system of schooling certainly does lit-
tle to diminish these inequalities among children: disparities in scores
on standardized tests typically increase with years of schooling.
In San Antonio Independent School District v. Rodriguez (1973) the Su-
preme Court ruled that state-funding formulae for schools based on
local taxes that generated large disparities in per pupil resources were
permissible under the U.S. Constitution.5 In this ruling the Court ef-
fectively sanctioned the unequal distribution of educational resources
for children, so long as the allocation was rationally related to a legit-
imate state interest, such as encouraging local control of schools. In
Rodriguez, the Court did, however, acknowledge the importance of se-
curing a basic and “adequate” education for all students, regardless of
the locality in which they live.
Since Rodriguez, “adequacy” has emerged as a new way of assessing
the distribution of school resources. State courts, along with state leg-
islatures, have enacted finance systems designed to ensure that all stu-

2. See Molly McCusic, “The Law’s Role in the Distribution of Education: The Promises
and Pitfalls of School Finance Legislation,” in Law and School Reform, ed. Jay Heubert (New
Haven, CT: Yale University Press, 1999), 88–159, 94.
3. See William Bowen and Derek Bok, The Shape of the River: Long-Term Consequences
of Considering Race in College and University Admissions (Princeton, NJ: Princeton University
Press, 1998), 341.
4. See Samuel Bowles, Herbert Gintis, and Melissa Osborne Groves, eds., Unequal
Chances: Family Background and Economic Success (Princeton, NJ: Princeton University Press,
2005) for a summary of the literature.
5. Rodriguez was initiated by parents whose children attended schools in the Edgewood
Independent School District, part of the metropolitan San Antonio area; see San Antonio
Independent School District v. Rodriguez 411 U.S. 1 (1973). At Edgewood, 90 percent of the
students were Mexican American and 6 percent were African American. Property values
were so low that even with a relatively high tax rate the district generated only $356 per
student. By contrast, neighboring Alamo Heights, a predominantly white district, had such
high property wealth that it could tax itself at a rate 20 percent below its poorer neighbor
and still have nearly $600 per student.

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 Satz Equality, Adequacy, and Education 625

dents achieve proficiency on state educational content standards. Al-

though there has been a large literature on the legal and practical
implications of the shift from equality of educational opportunity to
adequacy, there has been far less written on the normative implications
of this altered framework.
The difference between the adequacy and equity approaches to
education is usually drawn in terms of a logical distinction: whereas the
idea of equality is essentially comparative (it matters how much a given
person has with respect to others), adequacy is seen as essentially non-
comparative (it matters only that a given person has enough). Thus, on
this standard way of drawing the distinction, an egalitarian objects to
unequal educational opportunities because such inequalities are inher-
ently unfair, while a defender of adequacy aims merely to ensure an
educational floor—defined in terms of cognitive achievements and out-
comes. Additionally, adequacy has often been identified with only a low
threshold of achievement.
My main aim in this essay is to undermine the sharp contrast usually
drawn between adequacy and equality as goals of educational reform
and to offer reasons in support of an egalitarian conception of adequacy.
On my view, a certain type of equality—civic equality—is actually internal
to the idea of educational adequacy for a democratic society. An edu-
cation system that completely separates the children of the poor and
minorities from those of the wealthy and middle class cannot be ade-
quate for such a society. Educational adequacy, on my view, is tied to
the requirements of equal citizenship, in ways that I will spell out below.
My argument proceeds in four parts. In Section II, I review some
problems with educational equality of opportunity as a framework for
thinking about the distribution of educational resources. In Section III,
I present a conception of educational adequacy that has comparative,
egalitarian, and relational elements: in particular, my conception ties
adequacy to citizenship.6 I also argue that educational adequacy entails
that significant resources must flow to the least advantaged students in
our society. Thus, on my view, those who endorse an adequacy frame-
work because they are complacent about inequality or because they are
unwilling to devote additional resources to improving the education of
poor children are simply mistaken.

6. I am not the only theorist who has proposed a tie between the distribution of
educational resources and citizenship. However, my view emphasizes the egalitarian di-
mensions of educational adequacy. See Amy Gutmann, Democratic Education (Princeton,
NJ: Princeton University Press, 1987); Elizabeth Anderson, “Rethinking Equality of Op-
portunity: Comment on Adam Swift’s How Not to Be a Hypocrite,” Theory and Research in
Education 2 (2004): 99–110; and Goodwin Liu, “Education, Equality and National Citizen-
ship,” Yale Law Journal 116 (2006): 330–411. I am especially indebted to Anderson’s dis-
cussion of these issues.

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626 Ethics July 2007

In Section IV, I show that my conception of adequacy in education

has a number of advantages over competing frameworks. In particular,
adequacy for citizenship is necessarily about more than the distribution
of resources. A key strength of the adequacy perspective is its potential
to bypass the usual focus on allocating money and other divisible resources
and to focus directly on the institutional structures of education. In par-
ticular, because adequacy looks at the substance of educational outcomes
and not only at funding and opportunity, it opens the door on arguments
for the integration of schools by class and race. Not only is integration
by class and race causally related to the project of improving the perfor-
mance of poor students, but it is also a constitutive part of the idea of
civic equality. Segregated schools, by sharply dividing the advantaged from
the disadvantaged, tend to freeze a student’s economic and social position
at the level of his or her parents, prevent understanding across social
groups, and undercut the democratic idea that we are all civic equals.
Educational adequacy claims, while attractive, are not immune from
criticism. They still permit the children of wealthy parents to maintain
an educational advantage through schooling. So long as college schol-
arships, places in elite colleges, and good jobs are finite, children living
in school districts that can devote greater resources to education will
retain an advantage in the competition with poor children. Further-
more, adequacy seems to make the state complicit in promoting such
unequal advantages. In Section V, I examine what I believe to be the
most compelling objections to my conception of educational adequacy.

II. EQUALITY PARADIGMS

The idea of equality of opportunity has been a dominant thread in
public discourse about education and functions, in many respects, as a
fixed political ideal in American society. However, equal educational
opportunity is subject to very different understandings. There is, for
example, a good deal of disagreement about what it means for children
(or adults) to have equality of opportunities for education and em-
ployment success, with proposals ranging from securing the absence of
overt discrimination based on race and gender in schools to the far
more ambitious goals of eliminating all race, gender, and class differ-
ences in educational outcome. Thus, people who all accept the ideal
of equality of opportunity can differ on such issues as the legitimacy of
unequal school funding, tracking students by skill, and the permissibility
of private schools. Indeed, there are so many different interpretations
of the meaning of educational equality of opportunity that at least one
theorist has suggested that it might not mean anything at all.7

7. See Christopher Jencks, “Whom Must We Treat Equally for Educational Opportunity
to Be Equal?” Ethics 98 (1988): 518–33.

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 Satz Equality, Adequacy, and Education 627

I do not undertake a comprehensive survey of the many meanings

of the idea of equality of opportunity here.8 Instead, I review three
interpretations that have traditionally been associated with this idea in
educational policy and theory—nondiscrimination, horizontal equity,
and vertical equity. I am especially interested in examining the strengths
and weaknesses of the vertical equity interpretation, which I take to be
the strongest alternative to the view I defend here.

A. Formal Equality of Educational Opportunity: Nondiscrimination

The most minimally demanding equality of opportunity interpretation
is a formal one. Formal equality of opportunity requires that social
positions should be open to all applicants and that applicants be selected
on the basis of their qualifications for the position. It is a principle of
nondiscrimination. In employment, it means that applicants for a po-
sition should only be judged on the basis of their respective relevant
qualifications and not their race, class, or gender. Rawls refers to this
principle as “careers open to talents.”9
Formal educational equality of opportunity entails that no educable
child can be excluded from an education. It precludes an educational
system from distributing its positions on a discriminatory basis: it must
be open to all who can learn.10 Formal equality of opportunity in ed-
ucation (and employment) clearly marks a great achievement. But it is
also an inadequately narrow view of what equality of opportunity should
mean. This principle could be satisfied by a society in which only a small
elite had the opportunity to develop the necessary qualifications for a
given educational benefit. Adapting an example from Bernard Williams,
imagine an education system in which everyone has the chance to com-
pete for grades and honors but where the schools attended by poor
children are too ill-equipped—with unqualified teachers, outdated text-
books, and limited curricula—for these children to succeed in com-
petitive examinations. Such children may have no effective possibility
of becoming educated, let alone becoming competitive for college ad-
missions or highly skilled, high-paying jobs.11
There surely is something perverse in contending that equality of
opportunity in college admissions is fulfilled if many children never had

8. See Andrew Mason, “Equality of Opportunity: Old and New,” Ethics 111 (2001):
760–81, for discussion of the various understandings of equality of opportunity.
9. John Rawls, A Theory of Justice (Cambridge, MA: Harvard University Press, 1971), 65.
10. See Gutmann, Democratic Education, 127.
11. See Bernard Williams, “The Idea of Equality,” in Philosophy, Politics and Society, ed.
Peter Laslett and W. G. Runciman, 2nd ser. (London: Blackwell, 1962), 110–31. The
Harvard Civil Rights Project documents the many parallels between Williams’s imaginary
warrior society and our real educational system’s “savage inequalities.” (The quoted phrase
is of course Jonathan Kozol’s.)

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628 Ethics July 2007

the chance to acquire the necessary qualifications to enter college. The

appeal of equality of educational opportunity depends in some way on
the idea that, at some prior stage, individuals really had the possibility
of becoming qualified.

B. Horizontal Equity
Under this interpretation of equality of opportunity, all students are
entitled to the same amount of money from the government for any
government provided resource. The state is not permitted to be com-
plicit in inequalities of financial resources (although inequalities in pri-
vate resources are viewed differently by different theories). Plaintiffs
advocating greater equity in terms of this framework will be successful
when, for example, they succeed in replacing a state’s funding system
that is dependent on local property taxes with a system that generates
the same amount for any pupil in the state.
Although this interpretation of educational equality of opportunity
has had some limited legal and legislative successes, it is subject to three
obvious objections which have rendered it both difficult for courts and
legislatures to implement and conceptually unattractive. First, because
it does not specify a threshold of funding, this conception is compatible
with leveling educational resources downward for all. For example, in
California, a successful school finance equity case has been coupled with
a lower proportion of state revenue spent overall on education than
before its enactment.12
Second, it has been increasingly realized that equal financial inputs
may not yield equal resources: attracting good teachers to poorer schools
may require paying those teachers higher salaries than they would need
elsewhere. But even if resources are interpreted more broadly than
simply as cash—as including, for example, teachers, infrastructure, and
curriculum—an equal resources perspective ignores the fact that stu-
dents have different needs. Poor students in particular carry a higher
“load”—poor health, developmental disabilities, hunger, family disrup-
tion, and violence—which makes them more costly to educate. Third,
equal funding may not translate into equal education, insofar as the
school’s organization and infrastructure ensure that the money is badly
spent, with poor teachers and incompetent or corrupt leadership locked
into place in the school or school district.

C. Vertical Equity
Neither formal equal treatment nor horizontal equity, as we have seen,
gives us an attractive interpretation of equal educational opportunity,
especially if we take into account the differences in students due to their

12. Serrano v. Priest (Cal. 1971) 5 C3d 584.

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 Satz Equality, Adequacy, and Education 629

different genetic, family, and social circumstances. An alternative idea,

with wide appeal, is the idea that what equal opportunity requires is a
level playing field, in which all children have something like an equal
opportunity to compete for success. In his famous dissent in Rodriguez,
Justice Marshall invoked the idea of an “equal start in life” for all chil-
dren. Nevertheless, given that children come into the world with dif-
ferent innate abilities, as well as with different parents and social cir-
cumstances, the idea of what it means to have an “equal start” in life
or compete on a “level” playing field is not straightforward. It needs
interpretation. Below, I discuss two interpretations of this idea that have
tended to dominate the literature.
1. Meritocratic equality of opportunity.—An intuitive case for educational
equality of opportunity is desert based. Its unfair if some children get
more opportunities for educational achievement than others—and to
the rewards that such achievement makes possible—for reasons that are
arbitrary or irrelevant. The playing field is leveled—and the competition
for society’s occupations and rewards is fair—when only differences in
children’ talents, abilities, and motivations determine their educational
(and via education, their employment) outcomes. When such differ-
ences determine outcomes, children (and the adults that they become)
get what they deserve. I’ll refer to this interpretation of the level playing
field as meritocratic. In his recent book on schooling, Adam Swift ar-
ticulates a version of the meritocratic view: “Someone’s chances of get-
ting into a good university, or getting into a university at all, shouldn’t
depend on whether her parents are able and willing to send her to
private school. It should depend on how intelligent she is, and how
much effort she’s prepared to make when applying her intelligence.
The kind of equality of opportunity we’re talking about is meritocratic:
people with the same level of merit—IQ plus effort—should have the
same chance of success. Their social background shouldn’t make any
difference. If the lucky ones are jumping the queue, the unlucky ones
are necessarily losing out.”13 Although the meritocratic conception of
equality of opportunity has some intuitive appeal, it faces three serious
(and I believe decisive) problems: it cannot guide us in allocating re-
sources for K–12 education where “merit” is highly endogenous to
schooling; it would not offer a sufficient education with respect to either
children with little inborn talent or those who make poor choices; and
it has no real application to the lives of young children.14

13. Adam Swift, How Not to Be a Hypocrite: School Choice for the Morally Perplexed Parent
(London: Routledge, 2003), 24.
14. There is also a “radical” conception of meritocratic educational opportunity, ac-
cording to which talent and ability should not influence a child’s chances for educational
achievement, since talent and ability are not themselves deserved but are rather products
of a genetic lottery. Instead, on this view, a meritocrat should focus only on effort and choice.

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630 Ethics July 2007

The creation of merit: A central problem with using merit as a basis

for evaluating the distribution of school resources is that there is no
preexisting merit that is relevant to the question of who deserves to get
ahead, go to college, or get the best jobs. As Elizabeth Anderson notes
in her critical review of Swift’s book, the merit that matters in the case
of employment and university access is developed talent and ability, not
innate talent and ability.15 What matters, when selecting among appli-
cants for a job, is the applicant’s current qualifications for those posi-
tions. No one has any greater claim to an advantageous social position
than others simply because of her inborn talents.
Moreover, as a number of critics of this view have pointed out, the
creation of merit is highly endogenous to the distribution of educational
resources that we choose.16 If we choose to devote fewer resources to
courses in advanced mathematics, for example, we will thereby affect
the level of math ability in our society and change the talents that will
merit selection for jobs in university math departments. If a teacher
devotes more time to her less able students and less time to her more
able students, then she too can affect the meritorious abilities of her
students and thus change the order of the queue. Merit, therefore,
cannot tell us what the order of the queue should be, since different
distributions of resources will produce different levels of merit, which
in turn will determine who comes to stand first in line.
An aristocracy of talent? A second objection to the use of merit as a
basis of rewarding students with educational opportunities is that it is
not a demanding enough distributive principle for education in a de-
mocracy. This interpretation of the level playing field would offer very
little in the way of resources to those children who have few inborn
capacities or little educational potential. Consider the example of chil-
dren with cognitive impairments who cannot learn without the presence
of a teacher’s aide. It is compatible with the merit-based view that the
gap between these children’s abilities and those of other children will
substantially increase, and the so-called natural aristocracy of the tal-
ented would become a socially entitled aristocracy.17
Opportunity and children: A final problem with this interpretation of
equality of opportunity is that the language of merit and, indeed, of
“opportunity” seems misplaced in primary and at least part of secondary

15. See Anderson, “Rethinking Equality.”

16. Ibid.; see also Jencks, “Whom Must We Treat Equally.”
17. This objection might be met by an equality of opportunity theorist who acknowl-
edges the need for other principles governing the content and distribution of education.
Equality of opportunity need not be endorsed as the sole principle of education. I owe
this point to Harry Brighouse.

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 Satz Equality, Adequacy, and Education 631

school education.18 We expect children to go to school and master certain

capabilities; it is not enough that they have the opportunities to do so.
As Michael Walzer notes, “the goal of the reading teacher is not to
produce equal chances, but to achieve equal results.”19 The reading
teacher aims to teach all the children in his class to read, even the lazy
child. Moreover, society has an interest in securing certain achievements
in all children who are capable of attaining these levels of achievement.
A defender of merit-based equality of opportunity might grant chil-
dren’s limited agency and responsibility. What he would claim he wants
is not the equal opportunity for six-year-olds to read but rather that
each child be ensured access to the capacities that will enable them at
age eighteen to have an equal opportunity to compete for college. But
what does equal opportunity mean in this case, if we abandon the link
to an underlying and pregiven individual merit?
2. Equal development of potentials.—A different intuitive idea of the level
playing field would require that differences in where children wind up
at age eighteen should only reflect the differences in their underlying
potentials and not differences in their economic or social background.
Advocates of this view might seek to provide additional “weighted” re-
sources to students who face social obstacles to the development of their
potentials. There will, of course, be different ideas about which social
factors merit additional resources.20 In school finance litigation, some
proponents of vertical equity have argued that children raised in high-
poverty environments have a claim on the extra resources needed to
enable them to develop their underlying potentials on a par with their
wealthier peers. Vertical equity does not seek to track intrinsic merit
but rather to provide social resources such that all potentials develop
to the same degree (more or less).
This interpretation resonates with the democratic idea that all in-
dividuals are entitled to the same rights and freedoms regardless of
their social background. It also bears a resemblance to the principle
that Rawls calls “fair equality of opportunity”: it stipulates that individuals
with similar potentials born into different social classes should have
similar chances of occupying social positions.21 Nevertheless, the equal
development of children’s potentials among different social groups is
not plausible as a guiding principle for educational policy.

18. Stefan Gosepath pointed out the need to distinguish levels of education in my
argument.
19. Michael Walzer, Spheres of Justice (New York: Basic, 1983), 203.
20. See John Roemer, “Equality of Opportunity,” in Meritocracy and Economic Inequality,
ed. Ken Arrow, Samuel Bowles, and Steven Durlauf (Princeton, NJ: Princeton University
Press, 2000) for one conception. See also the “weighted student funding” approach which
has recently been developed by the Thomas B. Fordham Institute (2006).
21. See Rawls, A Theory of Justice, sec. 14.

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632 Ethics July 2007

Leveling down: It is certainly true that if educational resources were

improved for poor children, then they could compete for higher ed-
ucation and jobs on fairer terms. But even so, no society has the re-
sources to supply the same opportunities to poor families as are possible
for those with more wealth who value the continued development of
their children’s talents. As one child’s potentials expand more than
another’s, this principle will continually justify devoting more resources
to bring the now disadvantaged child up to the levels of her wealthier
peers. Yet no society can devote all of its resources to education, and
so at some point a line must be drawn as to how much the state is willing
to spend. Authorized democratic decision-making bodies will draw lines
that reflect the relative value they assign to education as opposed to
other social goods.
Assume that a level of funding based on a principle of vertical equity
is in place. Now suppose that some child’s parents propose to devote
additional resources to the development of their own child’s talents. If
the additional development of the child’s talents enhances overall pro-
ductivity, then this should, given appropriate social institutions, redound
to everyone’s absolute advantage. Suppose you and I are equal in un-
derlying potentials, but your parents invest in special lessons and that
leads your potentials to surpass mine. Although it may now be true that
my relative position with respect to a given opportunity is worse, my
absolute position may be better, if your additional talent increases the
size of the social surplus. It makes no sense to object to unequal talent
development simply because one’s own relative position is worsened.22
Efficiency considerations matter, even if they are not the only things
that matter. Increasing the life prospects of those born with little pos-
sibility of acquiring talent also matters. Ensuring fairness in competitions
between the super talented and the merely very talented seems less
important than ensuring that the life prospects of the worst off are
improved.23 While we can debate how much less important such con-
siderations are, many political and moral theories recognize reasons for
focusing on the least advantaged.24
There are other reasons to be wary of a principle that would level
talent down. There are numerous ways a person can benefit from the
cultivation of other people’s talents beyond the levels provided for by
public funds: these talents may make life more interesting and stimu-

22. See Anderson, “Rethinking Equality.”

23. See Richard Arneson, “Against Rawlsian Equality of Opportunity,” Philosophical
Studies 93 (1999): 77–112.
24. John Rawls has expressed some reservations about his earlier argument in A Theory
of Justice, according the fair equality of opportunity principle strict lexical priority over the
difference principle; see Justice as Fairness: A Restatement (Cambridge, MA: Harvard Uni-
versity Press, 2001), 163.

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 Satz Equality, Adequacy, and Education 633

lating, may give us a new sense of what human beings can achieve, and
may be valuable for their own sake. So, we had better have a clear
argument for why the unequal development of potentials is unjust.
The causes of inequality matter to our assessments: Is the unequal de-
velopment of children’s potentials necessarily unjust? There are many
factors involved in the fostering or stunting of children’s potentials.
These include the educational levels of the parents, parental income
and wealth, the transmission of personality traits, geographical location,
parenting styles, religion, gender, ethnicity, attractiveness, and health
status. It seems clear that the causes of differential starts in the “race”
of life (and of the corresponding differential development of underlying
potentials) are relevant to our assessment of the legitimacy of those
differentials.
In fact, data show that unequal educational outcomes are more
strongly influenced by exogenous factors than by school funding or by
schools themselves. The advantage of being raised in a middle-class
home is estimated at a half year’s achievement for every year of a
mother’s educational achievement beyond high school.25 Even with re-
spect to differences in parents’ financial resources on educational at-
tainments, recent scholarship suggests that the direct effect is probably
smaller than has been previously thought to the extent that parents are
not in extreme poverty and children’s basic material needs are met.26
Indeed, given the weak correlation between school funding and edu-
cational outcomes, it is difficult to understand why an advocate of a
vertical equity approach would focus on school funding issues.
Many factors outside schools affect children’s development. While
some of these factors are rightly subject to criticism (e.g., poor housing,
environmental toxins leading to bad health outcomes, etc.) others are
not objectionable. Consider parents who adopt religious conceptions
that differentially stress hard work, other worldly pursuits, or materi-
alistic consumerism. These different conceptions of life and value will
have different effects on the development of children’s talents. So will
parents’ decisions to raise their children in urban or rural settings.
Some equal opportunity theorists try to drive a wedge between
legitimate parental partiality in shaping children’s potentials and ex-
cessive and unfair partiality. Harry Brighouse and Adam Swift argue that
only insofar as parents’ advantaging child-development activities realize
the “relationship goods” of the family can they legitimately engage in

25. Gordon Berlin and Andrew Sum, Toward a More Perfect Union: Basic Skills, Poor
Families, and Our Economic Future (New York: Ford Foundation, 1988).
26. See Susan Mayer, What Money Can’t Buy: Family Income and Children’s Life Chances
(Cambridge, MA: Harvard University Press, 1997).

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634 Ethics July 2007

them.27 On their view, it is acceptable to read your child bedtime stories

but not to pay for your child to have a reading or mathematics tutor,
even if these activities have the same net effect on promoting the de-
velopment of your children’s potentials.
I do not think we should accept their argument. Many parents want
better education for their children—including private lessons—because
they believe that education is intrinsically valuable, not because they
want their children to be wealthier or more advantaged than their peers.
Their commitment to education does not stem from the desire to help
their children obtain competitive advantages in the job market but
rather from their appreciation of the good of education for personal
development. Or maybe they just don’t want to see their children bored
and unhappy in school. The Swift/Brighouse argument unacceptably
constrains those families with conceptions of the good that favor pro-
moting the education of their child—but lack the time to do the pro-
moting themselves.28 Dual-career families are likely to be especially con-
strained by their approach.
In fact, I believe that there is a deep tension within the ideal of
equality of opportunity, understood in terms of ensuring equal potential
development. Allowing equality of opportunity for talent development—
where parents who have received the resources necessary for the equal
development of their potentials must now bear the cost of their own
choices—leads to inequality of opportunities in the development of the
potentials of their children. Each of the choices that adults make in
their lives has some effect on the choices that will be open to their
children. What a parent values, where a parent lives, the career a parent
pursues, all will inevitably have some effect on the development and
shaping of her child’s potentials. We cannot secure the equal devel-
opment of children’s potentials while permitting a world with diverse
families, parents, parenting styles, geographical locations, and values.29

27. Harry Brighouse and Adam Swift, “Legitimate Parental Partiality,” unpublished
manuscript on file with author.
28. Brighouse and Swift (“Legitimate Parental Partiality”) argue that if a parent truly
values education, they should value it for everyone’s children, not just their own. Parents
who thus invest in their own child’s education really only value the education of their
own child, not education per se. But this conclusion does not follow. In a democracy,
representatives of citizens with diverse views about the priority of education over other
social goods vote on budgets. Parents who invest extra dollars in their own child’s education
might simply disagree with the majority’s decision about the appropriate size of the ed-
ucation budget.
29. Nor should we assume that the middle-class strategy of continually enhancing
children’s educational potentials are superior to other ways of bringing up children. See
Annette Lareau, Unequal Childhoods: Class, Race, and Family Life (Berkeley: University of
California Press, 2003), for a discussion of the strengths and weaknesses of different ways
of approaching children’s potentials. As Lareau emphasizes, there is nothing intrinsically

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 Satz Equality, Adequacy, and Education 635

III. ADEQUACY
The alternative to an equal opportunity view is an adequacy view. Ad-
equacy approaches typically focus on ensuring some threshold level of
education that must be achieved for all children. Many proponents and
some opponents of adequacy endorse the idea that educational ade-
quacy requires only a fixed and minimal threshold of achievement;
adequacy is widely viewed as compatible with significant inequalities
above this specified threshold of opportunity and proficiency. Critics
charge that adequacy simply ignores inequalities among students. As
two critics of adequacy in education put it, adequacy involves only “a
specific quantitative level of educational resources . . . to achieve cer-
tain educational outcomes based on external and fixed standards. It is
a measure that does not compare the educational resources or outcomes
of students with each other, but rather, looks only to some minimally
required level of resources for all students.”30
By contrast, I believe that if we reflect on the civic purposes that
we want a conception of educational adequacy to serve, we will endorse
only conceptions that contain comparative and relational elements.31
On my view, the idea of educational adequacy should be understood
with reference to the idea of equal citizenship. Education has long been
recognized as a “foundation of good citizenship,” a necessary condition
for full and equal membership in the political community. Education
is essential to the effective exercise of political rights. As the Court
reminded us in its Brown decision, education is required for the “per-
formance of our most basic public responsibilities,” and its denial ef-
fectively shuts out individuals from participation in society as citizens.32

preferable about maximizing potential: the issue is the extrinsic rewards that our society
places on educational attainment, an issue that I will discuss below.
30. William S. Koski and Rob Reich, “When Adequate Isn’t: The Retreat from Equity
in Educational Law and Policy and Why It Matters,” Emory Law Review 56 (2007): 545–617,
550.
31. The educational outcomes appealed to by courts and legislatures attempting to
determine adequacy vary widely. Some stress civic capacities such as the ability to vote and
to serve on a jury, others the capacity to compete in the labor market, and others the
ability to succeed in higher education. But many courts explicitly include comparative
criteria in defining adequacy. In one, the New York State adequacy rulings (2001), Justice
Leland DeGrasse struck down the entire New York State school financing system, arguing
that the idea of education for citizenship invoked by the New York constitution involves
“more than just being qualified to vote or serve as a juror, but to do so capably and
knowledgeably.” He also argued that minimal competency for any employment was not
enough but must include skills for “sustained productive employment.” The Ohio Supreme
Court declared in broad terms that children must be educated adequately so that they
are able to participate fully in society and directed the legislature to create an entirely
new school financing system with a significant infusion of resources to failing schools; see
Campaign for Fiscal Equity, Inc., et al. v. The State of New York (100 N.Y. 2d 893).
32. Brown v. Board of Education of Topeka, 347 U.S. 483, 493 (1954).

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636 Ethics July 2007

I define citizenship, following T. H. Marshall, in terms of the po-

litical, civic, and economic conditions that are needed to make one a
full member of one’s society.33 Citizens are equal in terms of their status
as full members, although they may be unequal along other dimensions
such as income and wealth. As full members of society, citizens (1) have
equal basic political rights and freedoms, including rights to speech and
participation in the political process; (2) have equal rights and freedoms
within civil society, including rights to own property and to justice; and
(3) have equal rights to a threshold of economic welfare and to “share
to the full in the social heritage and to live the life of a civilized being
according to the standards prevailing in the society.”34 Marshall asso-
ciated citizenship not only with political and civil rights—such as free-
dom of speech and political participation—but also with social and
economic rights—such as access to employment, health care, education,
housing, and a level of income essential to being, and being regarded
as, a full member of one’s society. Social and economic rights, in par-
ticular, work to substantially mitigate market inequality and serve to
underwrite our basic constitutional freedoms. If citizens are equals, then
no citizen should suffer a disadvantage in having access to these basic
rights as a result of her social background.
We can derive, in general terms, the nature and content of edu-
cational adequacy from the requirements for full membership and in-
clusion in a democratic society of equal citizens. First, citizenship re-
quires a threshold level of knowledge and competence for exercising
its associated rights and freedoms—liberty of speech and expression,
liberty of conscience, and the right to serve on a jury, vote, and partic-
ipate in politics and in the economy.
Second, the empirical content of this threshold itself depends on
the distribution of skills and knowledge in the population as a whole.
For example, what it takes to serve competently on a jury depends, in
part, on what other jury members know. Jurors need not only to com-
prehend and apply concepts like “reasonable doubt,” “negligence,” and
“probability” and be able to analyze statistical tables and graphs but also
to have the capability of responding to the arguments of other jurors
during their deliberations. Similarly, if students applying to college are
now expected to have knowledge of algebra, then those students who are

33. See T. H. Marshall, “Citizenship and Social Class,” in Class, Citizenship, and Social
Development: Essays by T. H. Marshall (Chicago: University of Chicago Press, 1977), 71–134.
Liu’s “Education, Equality and National Citizenship” called to my attention the importance
of Marshall’s classic essay on citizenship.
34. Marshall, “Citizenship and Social Class,” 78.

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 Satz Equality, Adequacy, and Education 637

not taught algebra are effectively cut off from college and the educational
and employment opportunities that depend on a college degree.35
Third, an education adequate for equal citizenship includes but
goes beyond the achievement of a narrow list of individual skills. A
society of equals is more than a collection of independent individuals
but includes the ways that people cooperate and relate to one another
in employment, in politics, and in making social decisions in their neigh-
borhoods and within public spaces. While some aspects of citizens’ com-
petence (e.g., numeracy, literacy, knowledge of history) can be achieved
by individuals alone, other competencies (e.g., mutual understanding,
mutual respect, tolerance) are group achievements, best accomplished
through the presence of diverse individuals. Individuals who are radi-
cally cut off from one another, in class- and race-segregated schools and
neighborhoods, will also lack the knowledge and perspectives needed
in both politics and in the economy.36 A society whose leaders come
narrowly from one social group will generally do a poor job in repre-
senting the interests of the diverse members of that society, interests
about which they may have no real information.37 Likewise, a person
who has no understanding of racial discrimination or poverty may do
a poor job in deliberating in a trial in which these matters are relevant.
Fourth, although an adequacy standard does not insist on strictly
equal opportunities for the development of children’s potentials, large
inequalities regarding who has a real opportunity for important goods
above citizenship’s threshold relegate some members of society to sec-
ond-class citizenship, where they are denied effective access to positions
of power and privilege in the society. Imagine a society in which all
citizens were educated to participate in social decision making but only
whites were educated enough to have access to the most fulfilling, well-
paying jobs or to serve as political leaders. Care must be taken to ensure

35. Robert Moses argues that when poor minority children are not taught algebra,
they are effectively cut off from the chance for a college education and access to key
positions in the economy. Young students need a floor—an acceptable amount of math
education in middle school that readies them for the college prep sequence in high school.
Moses emphasizes the “moving target” nature of this floor: the college prep math curric-
ulum differs from place to place, and it is changing; see his “Remarks on the Struggle for
Citizenship and Math/Science Literacy,” Journal of Mathematical Behavior 13 (1994): 107–11.
36. Not all forms of de facto segregation threaten the ideal of relations among equal
citizens. The social context of that segregation matters. Gender segregation in schooling
on the basis of girls’ purported impurity is a different matter than sending one’s daughter
to Wellesley.
37. There are as well indirect means by which we can learn about the lives of others,
including literature, history, film, and imagination. But while such means are important
components of education, they do not replace the need to integrate elites, a need that I
discuss and justify below. Thanks to an anonymous editor of Ethics for stressing the various
ways that we can learn about the lives of others.

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638 Ethics July 2007

that those with fewer opportunities are not at such a relative disadvan-
tage as to offend their dignity or self-respect, relegate them to second-
class citizenship, cut them off from any realistic prospect of upward
social mobility, or deprive them of the ability to form social relationships
with others on a footing of equality. Thus, an educational system that
simply precluded the students of poorer families from competing in the
same labor market and society as their wealthier peers cannot be adequate.
This ideal of equal citizenship does not require either equality of
resources or equal development of children’s potentials. Nevertheless,
it has distributive implications—although these are harder to state pre-
cisely than a principle of horizontal equality.38 While some inequality
in spending across districts and schools can theoretically be justified,
large differences in educational resources may effectively cut off the
bottom segments of society from effective access to society’s best op-
portunities and leading positions. On my view, then, adequacy is not
only a function of the bottom of the distribution but also of the top of
the distribution. Citizens are not equals when there is a closed inter-
generational social elite with disproportionate access to society’s posi-
tions of political and economic power. While my conception of adequacy
does not require that everyone have the level of education necessary to
gain entry into the top law schools, it does require that everyone with
the potential have access to the skills needed for college. And, to the
extent that even this criterion turns out to exclude pockets of society
where tradition orients people to manual labor and away from educa-
tion, then care must be taken to ensure that there are also multiple
routes to leading positions and multiple avenues of reward.39 In some
societies, for example, trade union leaders are frequently elected to
political office; in other societies, the social gradient is not so steep that
those with few skills are effectively excluded from access to significant
social benefits.
My conception of adequacy undercuts the sharp divide philoso-
phers often draw between sufficiency and equality. Consider a parallel
between my defense of an equality sensitive threshold (adequacy for
equal citizenship) and Rawls’s difference principle.40 Recall that the
difference principle stipulates that inequalities in resources are accept-
able so long as they contribute to the resources of the least well-off
person. Some theorists have interpreted this principle as establishing

38. As Harry Frankfurt once noted, “calculating the size of an equal share is plainly
much easier than determining how much a person needs to have enough”; see “Equality
as a Moral Ideal,” Ethics 98 (1987): 23–24.
39. An anonymous editor at Ethics pointed out that the requirement that all students
with the potential for college realize that potential may turn out to be unrealistic.
40. The analogy was suggested to me by Josh Cohen.

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 Satz Equality, Adequacy, and Education 639

only a floor of provision but providing few or no restraints on inequal-

ities above that floor. I believe that this interpretation is profoundly
mistaken. Rawls repeatedly stresses that “the social bases of self-respect”
are the most important resource to be secured by the difference prin-
ciple, more important even than income and wealth.41 The social bases
of self-respect form a central component of the difference principle’s
threshold—income and wealth are merely simplifying proxies when
ranking social positions. But the social bases of self-respect necessarily
involve relational elements: for example, what it takes to “appear in
public without shame” is dependent on what others have. Moreover, if
a child from a poor family knows that the state is willing to inject vastly
greater amounts of public monies into the development of wealthier
children’s abilities than hers—for no other reason than that they are
wealthier—she suffers from a dignitary injury that is unlikely to be com-
pensated for by income. Indeed, Rawls notes that the development of
our talents is a special kind of good, connected to the conditions that
support our sense of self-respect in a way that other goods such as
income are not.42
My point here is that Rawls’s difference principle is itself embedded
in a conception of justice that is meant to express a democratic idea of
society, a society of equal citizens. Rawls’s principle for ranking social
positions does not operate independently of the other parts of Rawlsian
theory—especially what Rawls calls the fair value of political liberty and
his fair equality of opportunity principle. What is sufficient to serve as
a social minimum is inevitably conditioned by the resources that others
have and what they can do with those resources. When some people
have a lot more, this may effect what others need to take part in com-
munity life. If this is so, then sufficiency is not logically distinct from
equality in Rawlsian theory.

IV. BENEFITS OF ADEQUACY FOR CITIZENSHIP OVER

EQUALITY OF OPPORTUNITY APPROACHES
Adequacy for citizenship has egalitarian dimensions. It requires that
education be distributed in ways that are consistent with equal civic
status, including fair (but not equal) access to opportunities above cit-
izenship’s threshold. Many of its practical implications are likely to be
similar to those endorsed by some equality of opportunity theorists.
Nevertheless, I believe that a focus on educational adequacy for citi-
zenship has some theoretical and policy advantages over the traditional
focus on educational equality of opportunity.
First, because adequacy for citizenship sets a minimum threshold

41. See Rawls, A Theory of Justice, sec. 67.

42. Ibid., sec. 65.

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640 Ethics July 2007

of attainment, it theoretically prevents states from spending down to an

equality of resources that leaves all schools without resources for meeting
adequacy’s educational standards.43 Although courts, legislatures, and
educators will inevitably disagree about the content of an adequate
education, adequacy in principle gives us standards and instruments by
which to hold public schools, and state policy makers, accountable for
delivering a level of education to all.
Second, because adequacy looks at the democratic purposes of ed-
ucation, as opposed to only focusing on providing equal opportunities
among individuals, adequacy is more congenial to the argument for
greater integration by class and race. The prevalence of separate schools
for rich and poor undercuts the primary lesson of democracy—that we
are all social equals. Indeed, as the Supreme Court noted in its sweeping
conclusion in the 2003 University of Michigan case on affirmative action,
there is compelling evidence that diversity is centrally important to pre-
paring students to function in a heterogeneous society.44
From the vantage point of the conception of educational adequacy
for equal citizenship, the neglect of the democratic purposes of edu-
cation is a key weakness of equality of opportunity approaches.45 If our
K–12 educational goals are, at least in large part, based on the require-
ments of equal citizenship, then schools have an important role to play
in encouraging intergroup knowledge, social integration, accommo-
dation, and understanding. These goals are not merely instrumental to
achieving more equal opportunities for poor children: they are also
constitutive parts of education in a democratic society of equals.46
Third, adequacy for citizenship can explain why some inequalities
require greater remedial attention than others, namely, those inequal-

43. While many states have reasonable education systems pocketed with some high
poverty, low achieving schools, some rural and poorer states have global problems in
educating their state’s children. In these states the problem is not so much funding
inequality between districts, but the low levels of funding for all schools. The Kentucky
finance litigation case Rose v. Council for Better Education, Inc. (790 S.W. 2d 186 [1989])
provides a model. The problem in Kentucky was not so much unequal educational re-
sources but a lack of resources overall. An equity perspective does not address such prob-
lems. Instead, we need an adequacy perspective to show that the state is failing to deliver
an adequate education to its children given existing levels of resources and so must increase
school funding, usually by raising taxes.
44. Grutter v. Bollinger 539 U.S. 306 (2003).
45. Thanks to Elizabeth Anderson for helping me to see this difference between
equality of opportunity approaches and those approaches which stress democratic
citizenship.
46. Integration has also been shown to boost the academic achievement of poor
children, beyond what is achieved by giving additional resources to poor schools. Equality
of opportunity theorists sometimes endorse integration as an instrumental value. I am
arguing, by contrast, that it is a constitutive feature of a democratic society.

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 Satz Equality, Adequacy, and Education 641

ities that affect the prospects of the least well-off. On my view, many of
the inequalities above citizenship’s threshold are not especially trou-
bling—consider inequalities in school funding between Beverly Hills
and Scarsdale; by contrast, inequalities that involve some people falling
below the requirements of full social membership are always of concern.
Equality of opportunity principles tend to view all inequalities as on par.
Fourth, on a practical level, adequacy for citizenship is a more
realistic standard for a diverse society. This principle recognizes that
individuals will disagree about the relative priority of education over
other social goods. As long as nonfederal decision-making bodies are
vested with the authority to finance education, there will be different
decisions about the levels of funding schools. At the same time, this
principle directs our attention to the education of the least advantaged
and to the education needed for full inclusion in society. Thomas Pogge
gives one example of how we might (partly) operationalize the adequacy
idea in education: we could examine how far below the median in
educational attainment children from poor backgrounds fall and adjust
educational spending to bring their outcomes closer to the median
level.47 This preserves the adequacy idea—focusing our attention on
those with the worst opportunities—but couples it with a focus on the
implications of wide educational attainment disparities for democratic
citizenship.

V. RESIDUAL CONCERNS
I now turn to address remaining concerns about an adequacy approach,
contrasted with an equality of opportunity approach. These concerns
are the positional nature of education, the role of the state in legiti-
mating inequalities, and the potentially negative consequences of an
adequacy approach.

A. Education as a Positional Good

Defenders of equality of opportunity will press objections to the residual
inequalities that even an egalitarian conception of adequacy seems to
leave intact. Rob Reich and William Koski argue that by allowing in-
equalities in educational opportunities to remain, adequacy actually
harms the worst-off members of society because education is a positional
good.48 Positional goods are goods whose value depends on relative

47. See Thomas Pogge, Realizing Rawls (Ithaca, NY: Cornell University Press, 1989),
172ff. Pogge is not concerned with adequacy here but rather with what he considers the
unrealistic standard set by Rawls’s fair equality of opportunity principle.
48. Koski and Reich, “When Adequate Isn’t.”

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642 Ethics July 2007

advantage.49 If everyone drove a Porsche, then the positional aspect of

having one would be erased (although the absolute quality standard of
everyone’s car would be improved).
So, one important argument against adequacy stresses the posi-
tional nature of education and the private returns that education con-
fers. When rich parents can send their children to private schools, or
better-endowed public schools, or supplement their children’s educa-
tion with private tutoring, this actually disadvantages other children
whose parents can afford less. Access to labor market and university
positions is essentially competitive, so that the greater worth of some
parties’ opportunities has a direct negative effect on the worth of the
opportunity for others. If we allow some parents to spend more on their
children than the society collectively undertakes to provide, then those
parents unfairly decrease the worth of the opportunities of the others.
Moreover, in our society, education is not only a necessary qualification
for high-paying forms of employment but also translates into health
insurance, greater vacation and leisure time, home ownership, and in-
creased mobility. Given the high stakes that are attached to high-paying,
skilled employment in our society, perhaps we should be worried about
the inequalities in educational resources that adequacy leaves in place.
How positional is education? The extent to which education is po-
sitional is contested, since many of the benefits of educational attain-
ment appear to be absolute: more education is arguably better than
less, no matter what others have. Nonetheless, education surely has some
positional elements, especially at the top end. There are many more
applicants for admission to elite colleges and universities than can be
accepted. Acceptance at an elite institution translates into not only pub-
lic goods for society but also private goods for the individual. Admission
to elite private universities also serves as a signal to employers about a
candidate’s skills, or at least about their ability to acquire skills.50
I think that this objection is the most compelling objection to an
adequacy view. However, this objection may be overstated, or it can be
countered without requiring equal opportunity. To see how it might be
overstated, consider that access to the higher education that translates
into jobs is only in some respects competitive; in others, it is not. In
fact, admission to most colleges in the United States is not competitive:
almost any high school graduate who applies will be admitted. Only a
small percentage of colleges and universities have competitive admis-
sions: according to U.S. News and World Report’s college issue, no more
than 100 colleges in the United States accept fewer than half of their

49. The term comes from Fred Hirsch, Social Limits to Growth (Cambridge, MA: Harvard
University Press, 1976).
50. Thanks to Jim Joyce for pointing out the signaling function of elite college education.

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 Satz Equality, Adequacy, and Education 643

applicants. In fact, higher education is more academically accessible in

the United States than in countries with more equal spending on
schools. American colleges admit more students with poor secondary
school records, offer to individuals many second chances to reenter
education, and offer a wider range of nonacademic instruction than
most of the other rich democracies. The main issue facing most Amer-
ican school children is not admission to college but preparation for
college, which adequacy addresses.51
Of course, if everyone had an education that was adequate for
college, college admissions might become more competitive across a
broader spectrum of schools. Thus, as Gerry Cohen once pointed out
about the freedom of the proletariat52—just because any single person
can escape from a life dependent on earning wages, it doesn’t follow
that everyone can escape—perhaps achieving adequacy in education
would only make the conditions for equity in education more relevant,
since now access to the elite colleges would be even more competitive.
Would the achievement of adequacy now fuel an arms race between the
more privileged parents and a further widening of the gap between an
adequate threshold and the top end of precollege education? Would
parents from Scarsdale and Beverly Hills resort to even more precollege
tutoring and funding if inner-city school children in New York and Los
Angeles now received a decent education? Perhaps, but I am unsure of
precisely what the causal mechanism here would be.
At any rate, adequacy, as I understand it, must be concerned with
ensuring that children from all walks of life are represented in society’s
leading institutions, including elite postsecondary universities and at-
tractive careers. A society of equals requires leadership positions be filled
by people from all parts of society, not only the most privileged. In a
democratic society, there are no fixed and frozen ranks, where “each
person is believed to have his allotted station in the natural order of
things.”53 If the inequalities in opportunities that adequacy permits fail
to integrate such privileged positions in universities and employment
across class and racial lines, then adequacy is not adequate to its purpose.
This is why adequacy views must look to not only the bottom of the
distribution but also to the top of the distribution. Children of all walks
of life must have a fair chance of obtaining the most privileged social
positions, including a fair chance at access to elite universities and the

51. Even if greater numbers of students from poor families were prepared for college,
there is a serious matter of the decreasing affordability of college for the poor. The
maximum federal aid for poor university students in 1996 had only 43 percent of the
buying power that the grant had in 1980.
52. Gerald Cohen, “The Structure of Proletarian Unfreedom,” Philosophy & Public
Affairs 12 (1983): 3–33.
53. Rawls, A Theory of Justice, 479.

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644 Ethics July 2007

career opportunities that depend on such access.54 The more that ed-
ucation is positional, the more that adequacy will converge with vertical
equality of opportunity views.
At the same time, because adequacy approaches tend to look at
school reform more holistically than those approaches focused on equal-
ity of divisible resources, adequacy may actually have more leverage to
narrow the gap between rich and poor. Adequacy for citizenship aims
at a high level of achievements, it has the potential to embrace proposals
aimed at breaking down class and race segregation, and it seeks to forge
relationships among diverse social groups. Students of all races who are
exposed to integrated educational settings feel much more comfortable
about their ability to live and work in a diverse society. When children
from poor families form relationships with children from middle-class
backgrounds, their own horizons and opportunities inevitably widen.55
The argument from the positional nature of education can also be
countered through social design. Indeed, it is worth stressing that ed-
ucation need not have the gatekeeping role that it currently serves for
many of our society’s highest positions. There can be, and often are,
diverse routes to success in life. In Sweden, for example, being a college
graduate is not a prerequisite for having a flourishing political career;
it is also possible to rise to high political positions because of one’s
experiences in the labor union movement.56 Even in the United States,
many of the most visible chief executive officers have not graduated
from selective colleges and universities.
Consider also that, according to the citizenship tradition repre-
sented by Marshall that I am endorsing, full membership in society
requires that individuals have access to certain goods as a right and
not as a reward for placing in the competition for elite education.
Marshall argued that there are strong reasons to provide a level of
health care, income, and security to all as a guaranteed right; they are

54. How much income differential is explained by having a degree from an elite
university rather than a noncompetitive one is contested. Stacy Berg Dale and Alan B.
Krueger (“Estimating the Payoff of Attending a More Selective College: An Application
of Selection on Observables and Unobservables,” Quarterly Journal of Economics 107 [2002]:
1491–1527) found that a school’s selectivity, as measured by matriculants’ average SAT
scores, does not correlate with students’ later income, once the abilities of the students
upon entering college are taken into account. This finding challenges previous studies
positively linking earnings to a college’s prestige.
55. See Richard Kahlenberg, All Together Now: Creating Middle-Class Schools through Public
School Choice (Washington, DC: Brookings Institution Press, 2001) for discussion of the
benefits of integrated education for all students but especially poor students. I was the
first member of my own family to attend college, and forming relationships with middle-
class students gave me a broader sense of possibility and freedom than I otherwise would
have had.
56. Thanks to Eleni Manis for raising this point in her discussion of my essay.

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 Satz Equality, Adequacy, and Education 645

the entrance tickets for inclusion in society as an equal citizen. To the

extent that in providing such rights we decrease the steepness of the
social hierarchy associated with education, we thereby decrease edu-
cation’s positionality.

B. State Complicity
It might still be objected that even if neither adequacy nor equality can
fully redress the competitive advantages that rich children have in ed-
ucation and employment, adequacy makes the state complicit in the
perpetuation of such advantages.57 By allowing richer districts to sup-
plement their finances through local parcel taxes or to unequally fund
schools in the first place, the state is now setting its stamp of approval
on inequality. It is bad enough for private individual factors to influence
children’s life prospects, but it is a far worse injustice if the state itself
is a party to the unfairness.
I agree that the state’s role matters: unequal outcomes that might
be acceptable when they are the result of private decisions can become
morally objectionable when sanctioned or codified by the state. There
is a strong prima facie case for the equal public provision of education;
as Brown put it, education must be provided by the state “on equal
terms.” Besides which, there is a shameful history in which the American
state made invidious distinctions between its citizens about the nature
of the education they were entitled to receive. Nevertheless, “on equal
terms” is a complex idea—or so I have argued. I have endorsed an
understanding of this phrase that links it to the equal status of citizen-
ship. And I have argued that such equal status can be compatible with
unequal funding, at least to some degree.
Consider the efficiency considerations noted above. If, by allowing
richer districts to supplement the levels that the state provides, there is
a greater social surplus produced which can improve the lives of the
least advantaged, then the state may be justified in facilitating such
unequal development of talent through unequal public funds. If au-
thority over schooling is to be decentralized, then this may entail giving
to local bodies input over funding decisions. The state’s subsidy of such
unequal funding through taxation must, however, be related to the
democratic state’s rational purposes: it cannot rest on the idea that the
children of wealthy individuals deserve more as such. I have also ar-
gued—in agreement with traditional equality of opportunity theorists—
that these considerations of efficiency and local power need to be
bounded: all children with the potential for college should be given the
education that will enable them to attend college—or if this is unreal-
istic, then there must be multiple routes to leadership positions—and

57. Thanks to Rob Reich for pressing this point in discussion.

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646 Ethics July 2007

inequalities in educational opportunities must not be so great as to

undermine the social respect of the least advantaged.
As a practical matter, given that school funding in the United
States occurs within individual states (who differ in their capacities
and/or willingness to fund education) and not through a federal body,
the national state is already complicit in inequality of educational
opportunities. To the extent that we vest democratic decision-making
power about the relative priority of education in local communities—
whether at the state or district level—we will inevitably have differences
in school funding across those communities. Adequacy, however, en-
sures that vigorous steps will be taken to prevent anyone with the
potential from failing to have the opportunities for college and that
the disparities in funding between states not undermine the ability of
students from these different states to compete on the national job
market.

C. Practical Negative Consequences of Employing Adequacy and Not Equity

Equality of opportunity has been an important rallying cry in our
nation’s educational history. It may be risky to give up that cry: talk
of “adequacy” may embolden those who are indifferent to the fate of
our nation’s poor children. While I have defended adequacy not only
on theoretical grounds but also on practical grounds, there is some
reason to be skeptical of its practical implications. Adequacy gives to
wealthy parents the ability to opt out of the effects of the public ed-
ucation system’s levels of funding by buying up better education for
their own schools. This, in turn, may actually encourage less than
adequate funding for the education of poor students and thus increase
the gap between the expectations of students attending different
schools. If the wealthy can decouple the fates of their own children
so radically from that of everyone else’s children, then in cases where
a single central decision needs to be undertaken in a state legislature
to determine funding for schools, the funding may actually be far lower
than if rich and poor saw themselves as standing in the same proverbial
boat. Allowing richer parents to opt out of the state-provided school
system, or insulate their children from its effects, may leave poor chil-
dren more vulnerable to less than adequate levels of educational re-
sources.58 I do not here assess the merits of this objection, but I think
that, in weighing the advantages of adequacy over equity approaches,

58. However, a system with no local supplementation may be politically difficult to

sustain as well, as it forces many voters away from their preferred spending levels.

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 Satz Equality, Adequacy, and Education 647

the practical policy consequences of each ultimately have to be con-

sidered.59

VI. CONCLUSION
I believe that an adequacy theorist can, to a significant degree, incor-
porate the aspirations of the level playing field interpretations of equality
of opportunity through an inclusion of relational and comparative con-
siderations. When the children of the poor do not have a fair access to
the educational and employment opportunities afforded to the rich,
they are effectively excluded from key parts of society. If adequacy means
adequate for democratic citizenship and for relations of civic equality,
then adequacy cannot focus only on the bottom of the distribution but
must also look to the top of the distribution.
Educational adequacy for citizenship directs us to distribute primary
and secondary schooling in terms of five criteria:
1. Secure an educational minimum, whose empirical content is de-
fined dynamically by the changing requirements for full member-
ship in society. These requirements must not be understood nar-
rowly as political capabilities but must also include capabilities for
sustained productive employment and solid prospects of living a
decent life.
2. Secure fair opportunities for educational and employment posi-
tions above the minimum. No social group should be relegated to
a second-class position, with access only to inferior and unreward-
ing schools and jobs. While fair opportunities need not be equal,
the extent of acceptable inequality of opportunity for access to
positions in society has bounds.
3. Secure the distribution of leadership skills among diverse social
groups.60
4. Develop the capabilities needed for cooperative interactions in a
diverse society. These include trust, tolerance, mutual understand-
ing, and mutual respect.61 To achieve these capabilities, we need

59. A full discussion of practical consequences of equality of opportunity and adequacy

views would also have to consider the possibility of middle-class withdrawal from public
schools into private schools. So long as society grants wealthier parents the ability of opting
out of the institutions of public education, then wealthy families will have some leverage
over the nature of school funding. It is highly unlikely that our society will ever abolish
private schooling. For a discussion of different models of school finance reform—with
and without local supplementation of funding—see Susanna Loeb, “Estimating the Effects
of School Finance Reform: A Framework for a Federalist System,” Journal of Public Economics
80 (2001): 225–47.
60. See Elizabeth Anderson, “Fair Opportunity in Education: A Democratic Equality
Perspective,” in this issue.
61. Anderson (“Fair Opportunity in Education”) stresses this point.

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648 Ethics July 2007

to move beyond an exclusive focus on resources and focus on in-

tegrating schools and neighborhoods across race and class divisions.
5. Avoid leveling down the development of talent and ability through
education, except insofar as this is necessary to get all children
with the requisite potential above citizenship’s high threshold.
While ensuring substantively equal opportunities in employment
and higher education is not required by this view of adequacy, there
must be enough access to the full range of society’s most favored po-
sitions to make possible the conditions for people to have egalitarian
social relationships. Thus, on my conception of it, adequacy is an egal-
itarian view.
Moreover, if it turns out that allowing wealthier districts to supple-
ment their educational resources through property and parcel taxes, or
through setting up tax-exempt private foundations attached to schools,
has the effect of creating less social support for adequate levels of state
funding, then adequacy itself condemns such funding inequalities. It
may be that aiming at more equal funding of education actually pro-
motes adequacy for citizenship.
The compatibility of the ideal of equal citizenship with significantly
differential resources pouring into the lives of children is an open ques-
tion. But it is clear to me that no egalitarian project for educational
reform can succeed without challenging the segregation of schools by
race and class. One way to undercut such de facto segregation of schools
would be to give students the right to attend the public school of their
choice, regardless of the neighborhood in which they reside. Another
way would be to challenge zoning laws that have the effect of excluding
the poor from middle-class communities. Still another would be simply
to close high-poverty schools and redistribute the children of these
schools into surrounding middle-class schools.62 To advance adequacy
for citizenship, we might also consider using policy instruments includ-
ing affirmative action, college outreach programs, adult learning pro-
grams, and top 10 percent admissions plans.63 Any view of education
that does not directly take aim at the structure of schooling in America,
where about a quarter of our children are isolated and segregated in
high-poverty, low-achieving, badly funded schools, cannot be adequate.

62. See Kahlenberg, All Together Now, for suggestions.

63. It is in fact unclear as to why a defender of equality of educational opportunity
would endorse adult education programs. But such programs are clearly important from
a citizenship perspective. I owe this point to Harry Brighouse.

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