Part 3 of a series

Cruz-Guzman and the Malatinszky Report, Part 3: The Cruz-Guzman Defendants Ignore the Broad Scope of Plaintiffs' Complaint

Recap

Part 1 of this series argued that no single reform lever — integration, funding, staffing, or curriculum — can by itself deliver a constitutionally adequate education; the causes of inadequacy are plural and interacting. Part 2 applied that framework to the Malatinszky report, arguing that the report asks the wrong causal question by treating racial imbalance as if it operated in isolation from the other conditions that shape student outcomes.

This post steps back to a more basic legal question raised by that critique: how does Minnesota law generally handle harm that has more than one contributing cause, and how does the Minnesota Supreme Court's most recent Cruz-Guzman decision handle it in the specific context of an Education Clause claim premised on racial imbalance? This defect is particularly significant, because the Cruz-Guzman Complaint is not limited to integration, but rather demands that Minnesota deliver a comprehensive remedy: to do what it takes to deliver an adequate education.

How Minnesota law ordinarily treats harm with multiple causes

Minnesota's general law of shared responsibility for indivisible harm is instructive, even though it arises in an entirely different doctrinal setting. Under the comparative fault statute, Minn. Stat. § 604.02, liability among multiple persons whose conduct contributes to a single, indivisible harm is generally several, not joint — but that default allocation depends on the harm actually being divisible among the contributing causes. Where a defendant wants to limit its own liability by apportioning the harm among multiple causes, the burden is on that defendant to prove both that the harm is capable of division and the specific share attributable to others. Rowe v. Munye, 674 N.W.2d 761 (Minn. 2004). If the harm cannot be cleanly separated into distinct, attributable shares, each contributing party remains liable for the whole of it. Id. The Minnesota Supreme Court's two Staab v. Diocese of St. Cloud decisions apply this same principle in the context of special-verdict apportionment among concurrent causes. Staab v. Diocese of St. Cloud, 813 N.W.2d 68 (Minn. 2012); Staab v. Diocese of St. Cloud, 853 N.W.2d 713 (Minn. 2014).

The animating idea is simple, and it is not limited to comparative-fault cases: when harm results from the interaction of several contributing causes and those causes cannot be neatly disentangled, the law does not let a contributor escape responsibility merely because other forces were also at work. The burden of proving that the harm can be divided — and how — falls on the party trying to limit its own responsibility, not on the party who suffered the harm.

Cruz-Guzman's different allocation of that burden

The Minnesota Supreme Court's most recent Cruz-Guzman decision confronts a structurally similar problem — an alleged harm (inadequate education) with potentially many contributing causes — but resolves the burden question differently.

The Court held that parents pursuing an Education Clause claim premised on racial imbalance in the Minneapolis and Saint Paul schools do not need to show that the State caused the racial imbalance itself. But the Court did impose a causation requirement running from the racial imbalance to the alleged educational harm. Borrowing from tort law's proximate cause doctrine, the Court adopted a “substantial factor” standard:

“[F]or a claim like this, with potentially many different causes of the alleged inadequate education — factors that may include racial imbalances — a ‘substantial factor’ standard is appropriate. The substantial factor standard recognizes the complexities and nuances of providing an adequate education. We therefore hold that to succeed on their Education Clause claim, the parents must prove that the racial imbalances are a substantial factor in causing an inadequate education.”

The Court's holding, as stated in its conclusion, was correspondingly narrow:

“[R]acial imbalances in Minneapolis and Saint Paul public schools, as compared to other schools in the same school district, are not sufficient, standing alone, to establish a violation of the Education Clause of the Minnesota Constitution. Although the parents do not need to prove that state action caused the racial imbalances, to succeed on a claim premised on racial imbalances they must prove that racially imbalanced schools are a substantial factor in causing their children to receive an inadequate education.”

In other words, where the comparative-fault framework places the burden of proving divisibility on the party trying to limit its own liability, the Court's Education Clause holding places something like the mirror-image burden on the plaintiffs: they must affirmatively isolate one strand of a multi-causal problem — racial imbalance — and prove that it independently clears a “substantial factor” threshold, notwithstanding the presence of other contributing causes.

The dissent's objection tracks the tort-law intuition

The Chief Justice's dissent makes essentially the point that Part 1 of this series makes about adequacy generally, and does so in terms that map directly onto the Rowe v. Munye divisibility problem. The dissent describes de facto segregation as the product of a “constellation of public and private forces, both historic and modern” — racially restrictive covenants, discriminatory housing finance, exclusionary zoning, wealth disparities, and bias, among others — and argues that requiring plaintiffs to prove racial imbalance is a substantial factor imposes a “two-stage” and arguably “Herculean” burden precisely because these causes, in the dissent's words, “might not be readily separable.” That is the same diagnosis that drives the divisibility rule in ordinary tort law — except that in Rowe v. Munye an inseparable, multi-causal harm works against the party trying to escape liability, while under the majority's Cruz-Guzman holding an inseparable, multi-causal harm works against the party trying to establish it.

Why this matters for the Malatinszky report

This is the doctrinal hook for the critique developed in Part 2. If the Court's substantial-factor standard requires isolating racial imbalance from the other contributing causes of inadequate education — funding adequacy, staffing, curriculum, and the rest — then an expert report that purports to supply that proof needs to actually engage the multi-causal structure of the problem: it needs to show that racial imbalance clears the substantial-factor bar net of the other forces operating on the same population of students, not merely that racially imbalanced schools and inadequate outcomes are both present. Part 2 argued that the Malatinszky report does not do this — that it treats racial imbalance as though it were the sole or primary variable, without accounting for the funding adequacy gap documented under the Skeen standard. The joint-causation framework discussed here is what makes that omission a legal problem, not just a methodological one: the “substantial factor” standard was adopted by the Court precisely because the causes of inadequate education are plural, and a report that does not test racial imbalance against the other candidate causes has not done the work the standard demands. The defense strategy is to convince the Court that integration alone cannot deliver an adequate education, and of course that is right. It fails to recognize that integration is part of a required solution, including funding, effective practices, and accountability. Its goal is to prevent the state from its constitutional responsibility by proposing that the court simply disposes of plaintiffs by ignoring the core demand of the complaint: that the legislature must provide an adequate education that meets all state standards.

The complaint itself is broader than the integration debate has treated it

Everything discussed above — the Supreme Court's substantial-factor holding, the dissent's divisibility objection, the Malatinszky report's causal framing — has unfolded inside a debate that treats the Cruz-Guzman litigation as, in essence, a school-integration-only case. That framing is understandable; racial imbalance is the theory the Supreme Court's most recent decision actually resolved, and it is the theory the Malatinszky report was commissioned to support. But it is not the only theory the plaintiffs pleaded, and the operative complaint — the Amended Complaint filed June 27, 2024 — is considerably broader than the integration remedy that has dominated the discussion.

The complaint's prayer for relief does not ask the Court to order integration only. It asks the Court to order defendants “to provide the plaintiffs forthwith with an adequate and desegregated education” — two distinct things, joined conjunctively, not one. Am. Compl. Prayer for Relief ¶ C. The word “adequate” is doing independent work in that sentence, and the body of the complaint bears that out, starting with the strict-liability count discussed in the prior post: Paragraph 74 pleads that defendants must remedy the deprivation of “an adequate education” without regard to whether they “caused or contributed to the deprivation” — a theory untethered to segregation or to any particular causal mechanism. And Paragraph 6, stated at the outset of the complaint, frames the case in exactly these terms: the defendants are obligated to act “regardless of whether the defendants have caused, contributed to, or are at fault for this inadequacy,” with the segregation-based causal theory offered only “alternatively.”

The complaint's allegations of harm likewise extend well past racial and socioeconomic composition into the operational conditions of the schools themselves — funding, staffing, and instructional capacity. Paragraph 39 alleges that the affected districts, because they must “devote disproportionately large resources to dealing with the many problems and difficulties that accompany poverty and racial segregation,” as a result “lack adequate resources to provide and maintain staffing, staff development, facilities, text books, science equipment, computers, sports and art programs, extracurricular activities, and other necessities and accoutrements of an adequate education.” That is a resource-adequacy allegation, not an integration allegation; it would remain true of a school with adequate racial balance but inadequate funding, staffing, or materials.

Paragraph 40 makes the same point using the State's own standards rather than comparative demographics: many students, the complaint alleges, “fail to perform at levels of adequacy accepted and recognized by the State,” such that “[t]he State has failed to educate these students both in comparison with other students and based on its own standards of what is adequate.” That is precisely the Skeen “all state standards” adequacy inquiry discussed earlier in this series — an inquiry that asks nothing about the racial composition of the classroom.

Paragraph 48(d) catalogs a list of practices the complaint alleges have “rendered increasingly difficult the provision of an adequate education,” including “misallocation of financial resources,” “discriminatory disciplinary procedures,” and “the improper and abusive use of Special Education services, alternative schools, Limited English Proficiency programs, magnet schools, charter schools, [and] tracking practices.” Several of these — financial misallocation, Special Education administration, and Limited English Proficiency programming in particular — are funding-adjacent and instructional-practice claims and they have nothing to do with integration as such.

Finally, the due process count in Paragraphs 71–72 rests on a theory that would apply to any inadequate school system regardless of its racial composition: because the State compels attendance and thereby “deprives students of their liberty,” due process requires that “the service be provided to them in an adequate form,” and the resulting “adequate education constitutes a property interest that the State may not abridge without due process of law.” Nothing about that theory depends on the presence or absence of racial imbalance.

Taken together, these allegations describe a complaint that seeks a comprehensive remedy — reaching funding, staffing, instructional practices, and the general conditions necessary to deliver an adequate education — of which the integration claim is one component, not the whole. The intense litigation and public attention devoted to the racial-imbalance theory, culminating in the Supreme Court's substantial-factor holding, has understandably crowded out attention to this broader pleading. But on remand, the district court will be adjudicating more than a segregation case. It will be adjudicating a case in which the plaintiffs themselves have alleged that inadequate funding, resource allocation, and instructional capacity are independent and sufficient grounds for relief — the very grounds this series has argued the Malatinszky report fails to engage. This failure is symptomatic of defendants' attempt to evade the constitutional responsibility to provide an adequate education.

Next in series

The next post in this series will address the Malatinszky report's proficiency-gap comparison and why it actually supports comprehensive relief including adequate funding, effective practices, accountability and, yes, integration.

Malatinszky's research Inadequate to Address Minnesota's Constitutional Adequacy Mandate

Part 2 of a Series • Cruz-Guzman and the Malatintsky Opinion

Integration Correlates. It Won't Deliver By Itself: What the Malatintsky Opinion Gets Wrong

Part 2 of a series on Cruz-Guzman and the Malatintsky opinion

In Part 1 of this series, we examined Minnesota's Skeen decision, which established a constitutional fundamental right requiring the legislature to provide enough funding.. In his proposed opinion testimony for the Cruz Guzman case, economist Malatinzsky attempts to show that integrated schools do no better than racially and economically isolated schools. But that research disregards the relief that Cruz-Guzman is asking for: integrated schools adequately funded, properly led, using effective practices, the full panoply of educational reforms.

Minnesota keeps looking for the single lever that will close its achievement gap. A better tenure statute. A better textbook. A more integrated classroom roster. Each of these has its advocates, and each advocate can usually point to real research showing that their reform, in isolation, correlates with better outcomes somewhere. But the evidence — and the last three decades of Minnesota litigation's futile efforts to deliver an adequate education — tells a more sobering story: no single component of the education system, changed on its own, can deliver an education that meets the state's own standards for a student who starts behind. It takes coordinated, rigorously implemented change across funding, staffing structure, curriculum, and school organization, operating together, sustained over time. Minnesota is not doing that, and the record shows it.

The bar moved. The delivery system didn't.

Until the early 1990s, Minnesota ran what is best described as a “seat-based” system. State law told districts how many hours a student had to sit in a classroom for a subject to count as a credit, along with some staffing ratios and licensure rules. It said almost nothing about what the student actually had to know when the bell rang. A district could hand out a diploma to a student who couldn't calculate ten percent of a hundred, and nothing in state law was violated.

Beginning in the 1990s, Minnesota — like Washington State and many others — abandoned that model in favor of proficiency-based standards: state-defined content standards, a testing regime to measure whether students actually meet them, and eventually programs like the LEAPS Act and dyslexia-screening mandates that specify not just what students must know, but what districts must affirmatively do to get them there.

But raising the bar and redesigning the delivery system are two different jobs, and Minnesota only did the first one. The state never went back and actually investigated what reforms are necessary to deliver the adequate education that the constitution requires, nor did it ask what it actually costs, in dollars and in organizational change, to bring a student who arrives years behind up to a proficiency standard designed around grade-level mastery.

Why a single fix can't close that gap

Once you accept that proficiency-based standards require more — more instructional time, more differentiated support, more skilled adult attention per struggling student — a second point follows almost mechanically: no single policy change supplies all of that on its own.

• Forslund v. State. The Forslund plaintiffs argued that teacher tenure and seniority rules were the constitutional problem — that ineffective teachers, protected by statute, were disproportionately assigned to disadvantaged students. Even accepting the premise, the claim asked a single personnel rule to carry the entire weight of the achievement gap — the Minnesota Court of Appeals dismissed the Forslund litigation, because the Plaintiffs had not established that merely abandoning tenure would result in delivering an adequate education.
• Cruz-Guzman v. State argued that racially and economically isolated schools were, in themselves, constitutionally inadequate, and that integration was the remedy. Racial and economic isolation is a real and serious problem, and it correlates with worse outcomes. But correlation is not the same as proof that integration alone — without also addressing funding, staffing, and instructional practice, without addressing learning time and high quality tutoring inside the newly integrated building — produces proficiency. A remedy aimed only at the seating chart doesn't answer that question.

As a result, Malatintsky's research is asking the wrong question. That integration alone does not produce an adequate education should be self-evident. But that doesn't address the relief that the Cruz-Guzman plaintiffs are seeking. They are seeking interation combinded with the other key deliverables, including the adequate funding required to implement a complex of reforms. Delivering an adequate education to students who come to school with significant educational challenge is difficult work that requires an all-hands-on-deck comprehensive solution. It may well be true that integrated schools are more likely to receive adequate funding, better teachers, more challenging courses, including advanced placement and gifted education. But it is not the integration that closes gaps; it is the radical improvement in all elements of the system accompanied by adequate funding accountably allocated to the things that work. Asking if integrated schools are producing better results than racially isolated schools doesn't address the Cruz-Guzman complaint, because Cruz-Guzman plaintiffs are seeking integration in combination with adequate funding, effective practices and all the rest. By integrating schools, we give everyone a stake in assuring that everyone's chldren get the resources and practices that are necessary for an adequate education.

What actually closes gaps

The research on schools that do successfully educate high-poverty, high-need populations to real proficiency points the same direction from the opposite side. Karin Chenoweth's studies of unexpectedly successful high-poverty schools describe a common pattern: schools organized as genuine collaborative teams, under strong instructional leadership, implementing a coherent and rigorous curriculum consistently across classrooms — not a talented teacher here or there working in isolation. Allan Odden and Sarah Archibald's work on doubling student performance makes the coordination requirement explicit: closing gaps at scale requires simultaneous change in school and classroom organization, curriculum, instructional practice, professional development, and how a district recruits, develops, and deploys its teachers and principals. Take any one of those away and the rest underperforms.

Odden's later research on how new money actually gets spent adds a warning that matters directly for Minnesota's budget debates: when new revenue is provided, districts have historically spent most of it outside the core instructional program — not on the differentiated instruction, tutoring, and additional learning time the research says disadvantaged students need, but on other priorities entirely. So even the funding half of the equation isn't self-executing. Money has to be paired with a deliberate, rigorously implemented instructional strategy, or it simply gets absorbed elsewhere without moving outcomes.

Put the two halves together and the standard for constitutional adequacy comes into focus: Minnesota is not failing its disadvantaged students because of one bad statute, one weak curriculum, or one segregated building. It is failing them because no branch of government has ever required — or funded — the combination of changes that the research says is necessary, sustained long enough and implemented rigorously enough to matter. That is the standard the next generation of litigation, including the questions raised in Cruz-Guzman and the Malatintsky opinion, has to be measured against.

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Next in this series

How Cruz-Guzman and the Malatintsky opinion do — and don't — grapple with this systemic requirement.

Malatinsky Challenges Cruz-Guzman's Claim that Segregated Schools Prevent a Constitutionally Adequate Education

Malatinszky Report Series · Part 1

Cruz-Guzman, Skeen, and the Charter Intervenors' New Expert Report

Part 1 of a series on the Malatinszky expert report in Cruz-Guzman v. State of Minnesota

Setting the Stage

On July 28, 2026, counsel for Higher Ground Academy — one of the charter school intervenors in Cruz-Guzman v. State of Minnesota — filed the amended expert witness report of Aron Malatinszky. This report is now a central piece of evidence in one of the most consequential pieces of education litigation in Minnesota history, a case that has been working its way through the courts for over a decade. To understand the legal context of that report, we need to understand the Supreme Court's Skeen and Cruz-Guzman decisions.

Skeen: The Funding Case

In Skeen v. State, 505 N.W.2d 299 (Minn. 1993), the plaintiffs — 52 school districts and ten parents — challenged Minnesota's school funding formula, arguing that wealthy districts could raise far more local revenue than poor ones, creating disparities the Education Clause of the state constitution didn't allow.

What the parties agreed to before trial. Early in the litigation, the parties entered into a formal stipulation — a set of facts both sides agreed were true for purposes of the case. That stipulation matters enormously to understanding what Skeen actually decided. The parties stipulated that Minnesota's K-12 system was "a system of education which meets contemporary standards for the accomplishment of all objectives associated with formal K-12 education," and, more specifically, that "all school districts in Minnesota meet state requirements set forth in statutes, rules, and policies." In other words, everyone agreed going in that the plaintiff districts were already delivering an education that satisfied every standard the state itself had set. Nobody was arguing the schools were failing to teach what Minnesota required them to teach. This stipulation occurred at a time when Minnesota had notoriously weak standards — standards that merely required students to attend a given number of hours allocated to various required subjects. Unlike today's standards, actually learning — proficiency — was not a state standard.

So what was actually being fought over? If the districts already met every state standard, where was the line between an adequate education and an inadequate one? That was the central question in Skeen, and the two sides answered it very differently.

The plaintiff districts argued that meeting minimum state standards wasn't enough. Yes, they said, we're teaching what the state requires — but because of funding disparities, we can't offer anything beyond that baseline the way wealthier districts can: no enrichment programs, no equivalent facilities, no equivalent opportunities. That gap, they argued, violated the constitution's uniformity and equal protection guarantees even though every district was technically compliant with state standards.

The State's answer was that equal funding was simply the wrong test. The State — not the courts, and not comparative wealth — gets to define what an adequate education consists of. Once the Legislature sets those standards and funds districts sufficiently to meet them, the constitutional duty is satisfied; anything beyond that is a matter for local choice and local tax effort, not a constitutional entitlement.

The Court sided with the State — but on the State's own terms. The "all state standards" language that now anchors this entire body of law comes directly out of that stipulation — the parties' own agreed language became the measuring stick the Court adopted. The Minnesota Supreme Court held that the Education Clause requires the Legislature to "provide enough funds to ensure that each student receives an adequate education," and that a funding system is constitutionally sufficient once it provides "an adequate level of education which meets all state standards." Because the plaintiff districts conceded they already met those standards, their claim failed — not because funding disparities didn't exist, but because the constitution doesn't guarantee equal funding, only adequate funding measured against the standards the state itself has adopted.

To recap: what "all state standards" actually meant in 1993. At the time Skeen was decided, Minnesota's state standards were remarkably weak by today's measure. There was no state proficiency requirement — no requirement that a third-grader be able to read, no statewide math or science benchmark. State standards amounted mostly to inputs: minimum school-day length, minimum instructional hours by subject, staffing and licensing ratios. Nobody was measuring what students actually learned; the state measured what districts offered.

That matters, because it means the "all state standards" the Skeen plaintiffs stipulated to meeting were, by modern standards, a low bar. But the Court did not treat that bar as a static, permanent definition of adequacy. In its brief to the Supreme Court, the Attorney General's office told the Court that Minnesota was in the process of abandoning those input-based standards in favor of rigorous, outcome-based learning standards — measuring what students actually learned, not just what they were taught or how many hours they sat in a classroom. As the State's reply brief put it:

"The trial court erroneously decided to base its decision on inputs rather than upon analysis of whether students are learning what they should be learning because it believed that outcomes are not as easily measured as inputs are. What is easiest almost always is not what is right. In fact, some important outcome-type measures are already easily quantifiable… Moreover, there is uncontroverted testimony in the record that the state is moving rapidly toward being better able to use outcome based standards to compare districts and students."

The State went further, arguing that constitutional adequacy should be judged against these emerging outcome standards — "that educational opportunity needed in a contemporary setting to equip a child for his role as a citizen and as a competitor in the labor market."

That representation to the Court is not a footnote to the Skeen holding — it's part of the foundation the Court built on. The Court adopted "all state standards" as the constitutional measuring stick with the Attorney General's own assurance, on the record, that those standards were about to become proficiency-based and outcome-based. In other words, Skeen's "all state standards" requirement anticipated — and was premised on — a state standards regime built around what students actually learn, not merely what districts provide. Minnesota did go on to adopt exactly that kind of proficiency framework in the years that followed. What the Legislature has never done is tie school funding to the cost of actually delivering it.

Two things about this holding are easy to miss, and both matter for everything that follows in this series.

First, courts don't write the standards — the Legislature and its agencies do, through statute, rule, and policy. But once those standards exist, the Legislature has an enforceable constitutional obligation to fund districts sufficiently to meet them. The adequacy line isn't a judicial invention; it's borrowed directly from the state's own definition of what schools are supposed to accomplish, and it's enforceable in court against the state.

Second, the Court held that this right isn't just good public policy — it's a fundamental right, enforceable in the courts, subject to the same demanding strict scrutiny the Court applies to only its most protected constitutional guarantees. As the Court put it, education is "a fundamental right under the state constitution, not only because of its overall importance to the state but also because of the explicit language used to describe this constitutional mandate," and any challenge to that right must be evaluated under "the strict scrutiny test," which a law survives "only if it is necessary to serve a compelling governmental interest." That's a serious constitutional hook — one the Legislature cannot satisfy simply by pointing to good intentions or budget constraints.

Cruz-Guzman: Does Integration Matter Too?

Cruz-Guzman asks a different question, building on Skeen's foundation. The plaintiffs are trying to convince the courts that the Education Clause requires something more than adequate funding against state standards in the abstract — that it also requires Minneapolis and Saint Paul school districts and charter schools to provide a racially and economically balanced education. In other words, that segregation itself, regardless of funding levels, is a constitutional problem.

In the case's 2018 trip to the Supreme Court — Cruz-Guzman I, 916 N.W.2d 1 (Minn. 2018), written by Justice Hudson for the Court — the justices held the parents' claims justiciable and, along the way, reaffirmed exactly what Skeen had established: that the fundamental right to an education "was not merely a right to anything that might be labeled as 'education,' but rather, a right to a general and uniform system of education that is thorough and efficient, that is supported by sufficient and uniform funding, and that provides an adequate education to all students in Minnesota." The Court added a further point worth keeping in view for this series — that "some level of qualitative assessment is necessary to determine whether the State is meeting its obligation to provide an adequate education," and that the judiciary "cannot fulfill our duty to adjudicate claims of constitutional violations by unquestioningly accepting that whatever the Legislature has chosen to do fulfills the Legislature's duty."

When the case returned to the Supreme Court a second time, in 2023, the Court didn't fully embrace the plaintiffs' integration theory, but it didn't reject it outright either. Writing for the Court, Justice Chutich held that racial imbalance in Minneapolis and Saint Paul schools does not violate the constitution per se — imbalance alone isn't enough. Instead, to prevail in their effort to reorganize schools and districts toward racial and economic balance, the plaintiffs must show that imbalanced demographics are a substantial factor in preventing students from receiving the adequate education that Skeen guarantees. Segregation has to be shown to cause the constitutional harm, not just correlate with it.

Justice Hudson, now Chief Justice, dissented from this part of the 2023 decision — she would have gone further and held that de facto segregated schools are themselves an inadequate education, without requiring separate proof of causation. That's her dissent, not the Court's holding, but it's a view worth keeping in mind as this series continues.

The Cruz-Guzman plaintiffs recognized that inadequate state funding might be part of the problem, but their overarching focus is on the claim that racial and economic imbalance in school populations is a substantial contributing cause of Minnesota's failure to provide an adequate education. Under the Court's 2023 decision, they can only obtain relief if they prove that imbalance is a substantial factor in causing an inadequate education. That causal question — does racial and economic imbalance actually prevent students from getting an adequate education — is exactly where the charter intervenors' new expert evidence comes in.

Enter the Malatinszky Report

It's in this context that Higher Ground Academy and the other charter intervenors have presented the opinion of their expert, Aron Malatinszky. His amended report was built to speak directly to the causal question Cruz-Guzman left open. Here's what it says.

Malatinszky was asked to answer three questions: how racially imbalanced are Minneapolis and Saint Paul's district and charter schools; are those schools performing adequately; and — the central question — is school racial composition a substantial factor in causing students to receive an inadequate education.

On imbalance, using 2024-25 enrollment data and a 15-percentage-point deviation standard borrowed from federal desegregation case law, he finds that many — though not all — MPS and SPPS district and charter schools are in fact racially imbalanced relative to their district's average.

On performance, using 2024-25 state assessment data, he finds that many schools are also identified by the state's own North Star accountability system as low-performing. District-wide, only 35.79% of tested Minneapolis students were proficient in math (40.79% in reading); in Saint Paul, the figures were 26.55% math and 34.82% reading. At the individual school level, the numbers are often starker still — a number of schools post proficiency rates in the single digits.

On causation, which is the heart of the report, Malatinszky turns to two decades of statewide longitudinal student data and a student fixed-effects regression design — a method that tracks the same students over time as they experience different school compositions, rather than simply comparing different students at different schools. His conclusion: he finds no meaningful causal effect, positive or negative, of school racial composition on student achievement. That finding, he reports, holds up across Black and Hispanic subsamples, across the Twin Cities metro area and the state as a whole, and across several different control specifications.

In plain terms: Malatinszky's opinion is that racial imbalance, by itself, is not what's driving the achievement gaps in Minneapolis and Saint Paul schools — and if that's right, it directly undercuts the causal showing that Cruz-Guzman requires the plaintiffs to make.

What's Missing — And Why It Matters

That's the report on its own terms. But a few things are worth flagging before anyone treats this as the last word on adequacy in Minneapolis and Saint Paul — and they'll be the subject of the next posts in this series.

The report never engages with Skeen's actual definition of an adequate education — one that "meets all state standards" — or with the fact that Justice Hudson's 2018 opinion for the Court reaffirmed that same standard, and insisted that some qualitative assessment of outcomes is unavoidable. Funding appears almost nowhere in the analysis; the only school-level inputs modeled are teacher characteristics, not dollars. And by the report's own numbers, a substantial majority of students in both districts are not meeting state proficiency standards at all — a fact that speaks directly to the Skeen adequacy question, independent of whatever the report concludes about race.

Next in this series: What Malatinszky's own proficiency numbers say about adequacy under Skeen — even before you get to the causation question.

Minnesota' K-12 Education System Needs Robust Accountability

Post 6 of 8 • Minnesota Education Finance Reform

This is the sixth post in an eight-part series on reforming Minnesota's K–12 education finance system, based on the Research Appendix I drafted for the 2025 MDE Task Force on Education Finance. Previous posts covered the history of inaction, the case for an adequacy study, weighted funding for high-need students, and the importance of evidence-based practices. This post addresses the accountability infrastructure that makes reform sustainable.

The Accountability Gap

Minnesota's school accountability system is built around the idea that competition and local control will drive improvement. Twenty years of data say otherwise. Recently, Minnesota legislators, politicians and pundits have attributed massive fraud to a lack of accountability. Minnesota's traditional public school districts are subject to a robust financial accountability system, and fraud is rare. However, when it comes to delivering an adequate education to students with higher educational needs, true accountability is largely missing. It might easily be argued, that the damage to Minnesota arising from lack of educational accountability is more serious than the financial fraud recently discovered.

By Gerald Von Korff • jvonkorff.com

Of all the elements of school finance reform, accountability is perhaps the most politically fraught. In Minnesota, accountability has long been equated with interference — an imposition of state mandates on the professional judgment of local educators and the democratic authority of locally elected school boards.

This attachment to local control is genuine, and the values behind it — community responsiveness, democratic governance, respect for teacher professionalism — are real. The problem is that those values, pursued without a parallel commitment to outcomes, have produced a system in which persistent failure continues without meaningful consequence. The students who suffer most are the ones with the least power to demand change.

This post examines Minnesota's current accountability system, explains why it has not worked, and describes what a genuine accountability infrastructure — one that supports and challenges local educators rather than simply watching from a distance — would look like.

What Minnesota's Current System Looks Like

Minnesota's accountability system rests primarily on two mechanisms: school choice and public reporting. The theory is that if parents can choose among schools, districts will compete for students and that competition will drive improvement. And if test scores and graduation rates are published publicly, embarrassment and community pressure will motivate underperforming districts to do better.

Neither mechanism has worked as intended.

Open enrollment and charter schools now serve about 10% of Minnesota's public school students. But the Research Appendix documentation is clear: school choice and charters have not produced the systemic changes necessary to make progress in closing the achievement gap. In 2024, the Minneapolis Star Tribune released a report criticizing the lack of accountability of Minnesota charter schools specifically. Competition has not driven system-wide improvement in outcomes for the students who need it most.

The public reporting mechanism — embodied most recently in the World's Best Workforce Act (now renamed Comprehensive Achievement and Civic Readiness) — has fared no better. A devastating 2022 report from the Office of the Legislative Auditor documented the system's fundamental inadequacy:

"Many schools see the WBWF report as a 'check-the-box activity,' not as a strategic planning imperative."
— Office of the Legislative Auditor, 2022

The auditor found that at the time of its review, MDE had allocated exactly one Full Time Equivalent staff position to World's Best Workforce administration. One person to oversee a statewide accountability system for over 2,100 schools. The auditor also found that MDE lacked any clear authority to intervene when districts set unambitious goals or failed to meet the goals they set. Districts were required to write plans. They were not required to implement them effectively. There were no meaningful consequences for failure. Recent data suggests that the MDE report to the legislature itself cost approximately $4,268 to prepare, including staff time, printing and mailing expenses. That's a very small figure for a statewide accountability report covering nearly 500 districts, suggesting the staff investment in review is minimal.

A January 2025 report summarizes how districts use these reports. It suggests that in many districts the CACR is indeed a check the box procedure.

Minnesota's Regional Centers of Excellence (RCE) represent the strongest element of the state's school support infrastructure. Staffed by specialists in literacy, math, special education, English language development, and school leadership, the Centers provide on-the-ground coaching and capacity building that goes well beyond what most districts could assemble on their own. By most accounts, their work is substantive and valued.

The problem is who they reach — and who they don't.

Under Minnesota's North Star accountability system, RCE support is triggered primarily for schools in the bottom 5 percent of Title I performance statewide, plus high schools with graduation rates below 67 percent. This is a deliberately narrow threshold, and the statewide proficiency data suggest it leaves a great deal of preventable failure unaddressed. As of 2025, fewer than half of Minnesota students are meeting grade-level expectations in math and reading — 43 percent in math and 48 percent in reading — essentially unchanged from 2023 and 2024, and proficiency rates remain roughly 10 percentage points below where they were before the pandemic. The Federal Reserve Bank of Minneapolis has described Minnesota's educational disparities as deep, wide, and persistent, noting that they span all parts of the state and all types of schools, whether district or charter.

Against that backdrop, a support system calibrated only to the worst 5 percent is not a system designed for broad improvement — it is a floor, not a framework. The hundreds of districts and charter schools operating in the middle tier, where proficiency rates are chronically low but not catastrophically so, receive no independent review, no external coaching, and no structured accountability beyond the self-reported CACR process described earlier in this post. The result is a large population of students attending schools that are failing them in measurable ways, with no systematic mechanism to trigger outside help.

The Minneapolis situation illustrates a second structural flaw, one that compounds the first. Twenty of Minneapolis Public Schools' roughly 96 schools were identified for comprehensive support — the highest level of state intervention — including 11 elementary schools. That concentration is striking: no other district in the state comes close to that number of comprehensively identified schools. Yet schools identified for support in Minneapolis work with their own district leadership on school improvement, while all other schools work with state-funded staff in the Regional Centers of Excellence.

This carve-out for large urban districts undermines the very logic of the support system. The RCE model exists precisely because outside expertise and independent perspective are essential when a school cannot diagnose and fix its own problems. Redirecting that support through the same district leadership that presided over years of underperformance removes the independent intervention that struggling schools most need. MPS is simultaneously managing a major school transformation initiative and a budget gap that required a one-time draw of $55 million from assigned fund balances — hardly conditions under which district leadership can be expected to mount rigorous self-directed improvement across 20 chronically underperforming schools.

Taken together, these two design choices — a 5 percent threshold that ignores widespread middle-tier failure, and a Minneapolis exception that routes improvement work back through the district itself — leave Minnesota's most vulnerable students with the least access to independent, expert support. A more effective system would lower the threshold for RCE engagement, establish periodic independent reviews for districts with persistently low proficiency regardless of their ESSA designation, and end the practice of allowing large urban districts to substitute internal management for genuine outside intervention.

The contrast with special education is stark: MDE maintains a comprehensive compliance monitoring system for students with disabilities — a five-year review cycle, active complaint adjudication (206 complaints since 2019), dedicated fiscal monitoring staff, and legal authority to require corrective action. For students of color, English Learners, and low-income students, no comparable system exists. The implication is that some students' rights to an adequate education are enforceable and some are not.

Local Control: The Argument and Its Limits

Advocates for Minnesota's local control approach argue that community-responsive governance produces better outcomes, that locally elected school boards provide genuine democratic accountability, and that state mandates stifle innovation. Some of these arguments have merit in specific contexts.

But there is a significant problem: Minnesota's strong local control tradition has produced deeply unequal outcomes, and average performance metrics — which tend to be high in Minnesota — mask that inequality. When the Minnesota School Boards Association points to Minnesota's above-average ACT scores as evidence that local control is working, it is describing the performance of the state's advantaged students. It is not describing the performance of students of color, English Learners, or students from low-income families, whose outcomes have stagnated for two decades.

Peter Cunningham, former Assistant Secretary of Education in the Obama Administration, has put the counter-argument plainly:

"In every important metric of success from student achievement to access to rigorous classes to high school and college completion, stubborn racial and economic gaps remain. The plain fact is that local control and quality control rarely go hand-in-hand... The absence of accountability breeds complacency."

Local control, without accountability for outcomes, protects the status quo. And the status quo has consistently failed Minnesota's most vulnerable students.

Two Models That Work

To understand what genuine accountability looks like, it helps to look at two systems that are producing results.

Department of Defense Schools (DoDEA)

DoDEA runs a worldwide school system serving 64,000 students. In 2022, by some measures, DoDEA students outperformed all 50 states on the National Assessment of Educational Progress — and were the only jurisdiction to see score increases during the COVID-19 pandemic. DoDEA students' demographics are challenging: high mobility, 50% qualify for free or reduced-price lunch, 80% have parents without college degrees. Their success cannot be attributed to advantaged student populations.

Minnesota Special Education

Minnesota's special education system demonstrates that robust state accountability produces results. Federal law requires a free and appropriate public education for students with disabilities, and Minnesota has built the systems to enforce it: five-year monitoring cycles, fiscal oversight, complaint adjudication, and dedicated staff with genuine authority to require corrective action. It is far from perfect, but it represents Minnesota's best existing model of what accountability for educational outcomes looks like.

What makes DoDEA work? Researchers have identified a clear set of success factors: centralized direction-setting paired with local decision-making; policy coherence and regular data flow on instructional goals and professional development; sufficient financial resources linked to instructionally relevant strategic goals; staff development that is job-embedded, intensive, and sustained; high expectations for every student; and a genuine organizational commitment to continuous improvement.

Notably, DoDEA's accountability system is not limited to test scores. All 50+ curriculum and student services programs are on a five-year review cycle. A dedicated Research, Accountability, and Evaluation office designs and analyzes surveys to assess the effectiveness of professional development. Schools undergo accreditation reviews that include in-person site visits. In 2021–2022, 40% of DoDEA districts earned Cognia's "distinction" designation — compared to 8% of other Cognia-accredited districts nationally.

As one education professor at Harvard told the New York Times: "If the Department of Defense schools were a state, we would all be traveling there to figure out what's going on."

What a Real Accountability System Would Look Like in Minnesota

Minnesota does not need to replicate DoDEA's military-adjacent structure. But it does need to build accountability mechanisms with genuine authority, adequate staffing, and a culture of continuous improvement rather than compliance theater.

Several elements are essential:

An independent oversight board with real authority. Modeled on Maryland's Blueprint Commission, this body would monitor implementation of funding reforms and evidence-based practices, require corrective action plans from districts that persistently fail to close achievement gaps, review how categorical funds designated for high-need students are actually spent, and report publicly to the Legislature. Advisory bodies without enforcement authority have been tried repeatedly and have not worked.

Substantially expanded Regional Centers of Excellence. These centers — which provide intensive, expert support to struggling schools — have demonstrated positive impacts on the schools they serve. But they currently reach only about 360 of Minnesota's more than 2,100 schools, with funding frozen at $1 million per year. The Legislative Auditor specifically recommended expanding funding and availability. A real accountability system provides not just consequences for failure but support for improvement.

Adequate MDE staffing for accountability functions. One FTE is not a serious accountability infrastructure. States that have made genuine progress on the achievement gap have invested in the state-level capacity to monitor, analyze, support, and — when necessary — require change.

Data systems that go beyond test scores. Accountability based solely on test scores misses critical dimensions of educational quality — including implementation fidelity for funded programs, graduation rates, attendance patterns, and post-secondary outcomes. Minnesota should develop the kind of comprehensive data infrastructure that DoDEA has built, making progress visible and actionable at the school and district level.

Accountability as Support, Not Just Surveillance

It is important to be clear about what strong accountability is not. It is not a punitive system designed to catch teachers and administrators doing something wrong. It is a support system designed to ensure that schools have the resources, knowledge, and expectations they need to succeed — and that when they are falling short, there is a pathway to improvement, not just a public shaming.

Odden and Picus, whose school finance research has informed dozens of state adequacy studies, put it well: the best results occur when district or school leadership embraces a culture of accountability — not as an external imposition, but as a fundamental commitment to the students they serve. Highly successful schools "believe it is their work on curriculum and instruction that produces improved student performance, and 'go back to the drawing board' when student performance does not rise."

That culture does not emerge spontaneously across all schools in all districts. It is cultivated by a state system that sets clear expectations, provides meaningful support, and holds schools accountable for results in a way that is consistent, professional, and focused on the students who are being failed.

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Next in the series → Post 7 of 8

Building for the Long Term: Continuous Improvement and Recalibration — Education reform is not a one-time event. The most successful state systems — Wyoming, Maryland, Kentucky — build in formal mechanisms to revisit, recalibrate, and improve their finance systems every few years as research evolves and conditions change. The next post explains why Minnesota needs a statutory commitment to continuous improvement, and what that looks like in practice.

Money is Necessary, But Not Sufficient: Evidence Based Practices

Post 5 of 8 • Minnesota Education Finance Reform

This is the fifth post in an eight-part series on reforming Minnesota's K–12 education finance system, based on the Research Appendix drafted for the 2025 MDE Task Force on Education Finance. Earlier posts covered the history of inaction, the case for an adequacy study, and why funding must be weighted to student characteristics. This post addresses what it means to spend money well.

Money Is Necessary — But Not Sufficient

The research is clear that adequate funding improves outcomes. It is equally clear that money spent on the wrong things does not. Here's what Minnesota must do differently.

By Gerald Von Korff • jvonkorff.com

A recurring argument against increasing education funding goes like this: we've tried spending more money, and it hasn't worked. The achievement gap persists. What schools need is better leadership, better teaching, higher expectations — not more money.

There is a kernel of truth in this argument. The research does show that, without accountability and guidance on effective practices, new funding can be absorbed into programs and practices that don't meaningfully improve student outcomes. Simply adding money to a dysfunctional system doesn't automatically fix the dysfunction.

But the conclusion drawn from this observation — that money doesn't matter — is wrong. What the research actually shows is more nuanced: money matters, and it matters most when it is paired with evidence-based practices and accountability. The three elements — adequate funding, effective practices, and accountability — are interdependent. Remove any one of them, and the others become much less effective.

This post focuses on the middle element: what it means to ground school funding in evidence-based instructional practices, and how other states have done it.

What the Research Says About Money and Outcomes

The debate about whether money matters in education has been conducted for decades, and the evidence has become increasingly clear. Dr. Bruce Baker of Rutgers University, whose work is among the most cited in school finance research, summarizes it directly:

"On average, aggregate measures of per-pupil spending are positively associated with improved or higher student outcomes... In direct tests of the relationship between financial resources and student outcomes, money matters."

A landmark 2015 study by researchers at Northwestern and Berkeley examined states where court-ordered funding reforms increased spending in underfunded schools and found that increasing per-pupil spending by 10% across all twelve school-age years increased the probability of high school graduation by 7 percentage points for all students, and by roughly 10 percentage points for low-income students. For low-income children, that additional spending also boosted adult wages by about 13%. These are large, sustained, real-world effects.

More recent research reinforces this finding. A 2018 study using national NAEP data found that school finance reforms that increased funding in low-income districts caused sharp, immediate, and sustained increases in student achievement. The effects phased in over several years following the reform — consistent with the reality that educational improvement is gradual — but they were real and substantial.

However, the same body of research also documents that money spent ineffectively can have little or no impact. The question is not whether to spend more — it is how to ensure that additional spending is directed toward practices that actually work.

Evidence-Based Funding: What It Means

The leading approach to connecting funding with effective practices is called Evidence-Based Funding (EBF). Developed and championed by school finance scholars Allan Odden and Lawrence Picus, EBF works as follows: rather than setting a funding level based on historical spending patterns or political negotiation, the state identifies the specific programs, staffing configurations, and services that research shows are effective, prices them out, and funds schools at the level required to implement them.

This approach does more than calculate a cost. It provides direct guidance on how money should be used — what teacher-student ratios are supported by research, what intervention programs have proven track records, what professional development structures lead to sustained improvement. It connects the dollar amount to the educational strategy.

EBF has been adopted, in various forms, in Illinois, Wyoming, Arkansas, New Jersey, and many other states. Each implementation is tailored to state-specific standards and conditions, but all share the core principle: funding levels are derived from an evidence-grounded analysis of what it costs to deliver effective education, not from what the Legislature happened to appropriate last year. None of these states have implemented evidence based systems fully, or perfectly. Minnesota could do it better, if we implemented it more faithfully. In some iterations, the evidence based funding system has failed to pair evidence based practices with promised increased funding. If Minnesota implemented EBF, we would have a head start over other states, because our finance system is closer to fair than most others.

I would like to be crystal clear: I'm not asserting that Wyoming, Illinois, or Arkansas have vaulted their educational systems to acceptable levels. Each has experienced major challenges and obstacles. Often they have failed to properly fund the evidence based practices that EBF has identified. The fundamental difference in these states worth studying, however, is that they start with identifying evidence based practices necessary to achieve educational goals and then proceeded to estimate the amount of funding required to fund those practices. This is completely foreign to Minnesota's approach. Indeed Minnesota has intentionally, wilfully, avoided any attempt to base funding on the educatonal practices and programs necessary to provide students with an adequate education that meets all state standards.

What Other States Have Done

Illinois

Illinois enacted a historic Evidence-Based Funding reform in 2017. The Legislature created a Professional Review Panel — composed of practitioners, experts, legislative leaders, and advocates — to regularly review and recalibrate the funding model. The state also created a Balanced Accountability Measure Committee to develop recognition standards for student performance and school improvement across all districts. The reform has directed hundreds of millions of new dollars to the state's most underfunded districts, with the explicit requirement that those funds support evidence-based programs. Illinois publishes the research summaries underlying its EBF recommendations, so districts can understand not just what they are expected to do, but why.

Critics of Illinois implementation have argued that Illinois' Evidence-Based Funding (EBF) formula is significantly underfunded, with a gap of approximately $5.7 billion as of late 2025. Despite the 2017 law intending to provide adequate resources to schools, particularly high-poverty districts, consistent underfunding means roughly 3.3 million students attend schools that do not meet the mandated funding adequacy level.

Maryland

Maryland's Blueprint for Maryland's Future, enacted in 2021, committed $3.9 billion in additional K–12 funding over ten years — paired with explicit accountability provisions requiring that funds be used for evidence-based practices. The Blueprint includes guardrails to ensure that money designated for high-need students actually reaches high-need programs, not administrative overhead or programs without evidence of effectiveness. Maryland's approach also includes an independent oversight board (discussed more in the next post) with authority to require course corrections when implementation falls short.

Maryland's Blueprint for the Future has faced mounting fiscal and political headwinds as it works toward full implementation by 2032. When state financial officials determined in December 2024 that Maryland would face a roughly $3 billion deficit in fiscal year 2026, Governor Wes Moore proposed scaling back parts of the Blueprint, including temporary pauses on plans to give teachers more collaborative planning time, reduced funding for English learner programs, and a two-year freeze on community school funding. The resulting debate in the 2025 General Assembly session was among the sharpest of the year, with the governor and lawmakers — particularly the House — deeply divided over how much to cut. A compromise bill ultimately passed, but the relief is only temporary: while Blueprint spending is covered in the next two years, funding in subsequent years is set to shift to the state's general fund, where projected deficits could reach $3 billion by fiscal 2030. Critics and advocates alike have noted a pattern of legislative procrastination: each session, revenue solutions are proposed to close structural gaps, but lawmakers have done just enough to keep the program afloat for another year rather than securing long-term financing — leaving the Blueprint's ambitious goals chronically underfunded even as its 2032 deadline approaches.

Wyoming

Wyoming has contracted with a consulting team to recalibrate its Evidence-Based Funding model every five years since 2005 — making it one of the longest-running continuous adequacy and effectiveness review processes in the country. Each recalibration incorporates updated research on effective practices, revised cost estimates, and analysis of what has and hasn't worked in Wyoming's specific context. The process ensures that the state's funding system evolves with the evidence rather than calcifying around outdated assumptions.

The state has consistently ranked among the top ten to fifteen states nationally in per-pupil spending, though that figure is substantially inflated by Wyoming's small enrollment, vast geography, and historically strong mineral tax revenues rather than reflecting an unusually generous education policy. In recent years the gap between what the model recommends and what the legislature actually appropriates has become a flashpoint. During the 2025-26 recalibration cycle, the Select Committee on School Finance cut the consultants' recommended funding increase from roughly $100 million down to about $12 million, drawing sharp criticism from the governor, school districts, and educators who argued the legislature was using the recalibration process to cut education spending rather than honestly assess what a constitutionally adequate education actually costs.

State Mandated Effective Practices

Evidence based funding is an approach that ties funding to effective practices. There has been considerable resistence to state effective practices directive in Minnesota. However, our failure to address the literacy gap, and a corresponding concern with the lack of the adoption of science of reading principles ultimately led the legislature to adopt the Minnesota Read Act. A first nod towards mandating effective practices, but with no connection to funding based on cost. Whether Minnesota has the will systematically and robustly implement any effective practice mandate,and whether Minnesota will provide funding based on cost remains to be tested.

Early anecdotal results are encouraging, but the chances for cost based funding are not. Teachers across the state are being trained in a unified, evidence-based approach. Districts that had been using curricula misaligned with the science of reading are being required to change. The statewide focus has created momentum and shared purpose that fragmented, locally-determined approaches could not generate.

"Tens of thousands of public school teachers in Minnesota are on the same journey... Concerned about test scores showing a decline in the reading performance of Minnesota children since just before the COVID-19 pandemic, the state in 2023 passed the Read Act, requiring all Minnesota schools to train their teachers in the structured literacy approach... the initial results are encouraging."

The Read Act is not perfect. A 2024 report by Minnesota's Literacy Team found that 68% of districts reporting on their reading curriculum were still not using materials fully aligned to the Science of Reading. Full implementation will require sustained effort, monitoring, and support. But the model — state establishes evidence-based practice requirements, funds training, monitors implementation — is exactly right.

The 2026 legislative session shows a consistent pattern — complaints about the READ Act being an underfunded burden are coming primarily from Republicans and district administrators, while DFL legislators have tried to respond with supplemental appropriations. The tension between the mandate's ambitions and available funding has been a recurring theme throughout the session. Once again, Minnesota has utterly failed to determine the cost of implementation and fully fund it. Our failure to connect adequate funding, once again, threatens even this critical reform

The key insight: The Read Act will work fd it doesn't just tell districts what outcomes to achieve — but tells them what practices are required to get there, and then funds the infrastructure to support those practices. This model should be extended to mathematics education and Multilingual Learner programming, where similar evidence bases exist and similar gaps in practice persist.

The Accountability Connection

Evidence-based practices without accountability become suggestions. States like Maryland and Illinois have recognized this: they built guardrails into their funding reforms specifically to ensure that money designated for high-need students and effective programs actually gets used for those purposes.

Odden and Picus, whose school finance work is among the most widely cited in the field, put it plainly: it is critical that adequate funding be paired with an obligation by schools to implement effective practices. Funding without that obligation allows well-intentioned dollars to flow into activities that are comfortable and familiar but not necessarily effective.

This is not a criticism of educators. Most teachers and administrators are working hard and want their students to succeed. The problem is that without a structured framework connecting funding to specific evidence-based practices, schools default to what they already know — even when research points clearly toward something better.

The next post addresses accountability more directly. But the evidence-practice connection is worth stating here: the reason accountability matters is precisely because it enforces the link between the funding we provide and the practices we've determined are most likely to help students achieve.

A Note on What "Evidence-Based" Means

It is worth being clear about what evidence-based practices are and are not. They are not a single rigid curriculum or a top-down mandate that eliminates teacher professional judgment. They are an evidence-grounded framework — a set of instructional approaches, program designs, and organizational structures that research has shown to be effective across a range of settings.

Within that framework, there is substantial room for local adaptation, teacher creativity, and responsiveness to the specific needs of each school community. The science of reading, for example, establishes what the building blocks of effective literacy instruction are — phonemic awareness, phonics, fluency, vocabulary, comprehension. It does not dictate how a teacher engages with a particular student on a particular day.

The goal is not uniformity. It is effectiveness — and effectiveness grounded in evidence rather than habit, tradition, or ideology.

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Next in the series → Post 6 of 8

The Accountability Gap — Even with adequate funding and evidence-based practices, Minnesota's achievement gap will not close without a genuinely robust state accountability system. The next post confronts the state's deep attachment to local control, examines why that attachment has not produced systemic improvement, and describes what a real accountability infrastructure — one modeled on special education compliance and the Department of Defense school system — would look like.

Minnesota is not Funding the Actual Needs of Students

Post 4 of 8 • Minnesota Education Finance Reform

This is the fourth post in an eight-part series on reforming Minnesota's K–12 education finance system, based on the Research Appendix drafted for the 2025 MDE Task Force on Education Finance. Post 1 introduced the series; Posts 2 and 3 covered Minnesota's history of inaction and the case for an adequacy study. We have pointed out that the 2004 finance study urged that the legislature should fund the "full dollar cost" of educating each student, and that the Skeen decision ruled that the constitution demanded the legislature to provide districts with enough funding to provide an adequate education that meets all state standards. This post addresses how funding must be tailored to the real cost of educating each student and how the state fails even to try to meet that standard.

In the prior post, we identified two methods of estimating the full dollar cost of delivering an adequate education. But there is another method largely ignored in Minnesota and elsewhere. Every district in Minnesota serving students of color, lower income students, English language learners, and/or students with disabilities is spending way more money, per student, than the state supplies for those students education. Most of them are stretched and would like to be able to spend more. Since each of those district is spending more than the state is supplying, surely it is reasosonable to conclude that what they are spending is compelling evidence of the minimum amount of money necessary to provide those student with an adequate education. The real question is how much more than they are spending, constrained as they are, would be required to provide that adequate education.

Funding Students, Not Just Schools

It costs more to educate some students than others. Minnesota's funding system doesn't reflect that — and the students paying the price are the ones who can least afford it.

By Gerald Von Korff • jvonkorff.com

There is a principle in education finance that sounds almost obvious once you state it: it costs more to educate a child who arrives at school three grade levels behind than a child who arrives ready to learn. It costs more to serve a student who doesn't yet speak English than one who does. It costs more to educate a child living in deep poverty — with all the health, nutrition, housing, and family instability challenges that poverty brings — than a child whose basic needs are reliably met.

This is not a liberal or conservative position. It is arithmetic. And it has significant implications for how Minnesota funds its public schools.

Minnesota's current system acknowledges this principle in theory — it provides categorical supplements for certain high-need student populations. But those supplements are set at levels determined by political compromise, not by rigorous analysis of what education actually costs for these students. The result is a systematic underfunding of exactly the students who need the most support.

The Historical Shift That Changed Everything

To understand why weighted student funding matters so much, it helps to understand how the cost of education changed when Minnesota — and the country — shifted from seat-time to proficiency-based standards.

Before the 1980s, Minnesota public schools were legally required to deliver required course content in a minimum number of hours of instruction. That was the standard: show up, teach the curriculum, maintain the required student-teacher ratios. Under that model, it was expected and accepted that students would perform very differently. Some would thrive; some would struggle; some would fall through the cracks. No one was held responsible for closing the gap.

In 1983, Minnesota began transitioning to a proficiency-based system — one that holds schools accountable not for the instruction they provide but for the learning that results. All students are expected to reach minimum standards of proficiency in core subjects. The state now mandates reading at grade level, math proficiency, and graduation. Schools are judged on whether their students achieve those outcomes.

This transition was the right thing to do morally and economically. But it fundamentally changed the cost structure of public education. Under seat-time standards, a trained teacher with an appropriate curriculum was essentially sufficient. Under proficiency-based standards, a school serving students who are significantly behind — whether due to poverty, language barriers, disability, or other factors — must do dramatically more to achieve the same outcome: more instructional time, more intervention services, more support staff, more family engagement, more individualized attention.

"If students are behind, or must overcome barriers to successful learning, they need more services, more time learning, and more support, and therefore significantly more funding."
— Thomas Fordham Institute, "Fund the Child" (2006)

This conclusion comes not from progressive advocates but from the Thomas Fordham Institute — one of the country's most prominent conservative education think tanks. When even ideological conservatives acknowledge that high expectations for disadvantaged students require more resources, the debate about whether weighted funding is necessary should be settled.

The Students Minnesota Is Underfunding

Students from Low-Income Families

On average, students living in poverty arrive at school with accumulated educational deficits — less early childhood preparation, more health and nutrition challenges, more frequent mobility, less access to out-of-school enrichment. Closing those gaps requires significantly more instructional support, earlier intervention, and extended learning time. Research consistently shows that the additional cost of providing an adequate education to low-income students double the base cost for more advantaged students or more.

English Learners / Multilingual Learners

Students who are still acquiring English require specialized instruction, bilingual support staff, and additional time. Minnesota's current ELL funding creates what researchers describe as a "cross-subsidy" — districts are required to spend far more on ELL services than the state provides, meaning other programs are effectively subsidizing ELL education. The 2020 Walz administration report recommended reducing this cross-subsidy to no more than 50% by adjusting per-student funding and lifting the cap for inflation. That reform has not been fully implemented. The 2023 legislation represented a major step forward — nearly doubling the per-pupil EL allowance and creating a new cross subsidy aid component starting FY 2027 — but that new component only reimburses 25 cents on the dollar of the remaining gap, so a significant cross subsidy burden remains. A district's cross subsidy, as measured by the state, is not the difference betweeen providing an adequate education to ELL's, its merely the difference between what the district is spending and the amount of reimbursement. Other than a potential constitutional claim, there is no practical mechanism to assure that districts are allocating adequate funding to English language learners.

Students with Disabilities

Special education is treated differently. State and federal law demands that districts provide the adequate education the law demands, but purposely underfunds the cost. Students and their parents are afforded a right afforded to no other student: to seek administrative or judicial relief to force the district to provide a free and appropriate education. As a result, Special education is the one area where Minnesota has built a relatively robust state accountability and funding system. Federal law requires a free and appropriate public education for students with disabilities, and the state has developed compliance monitoring, fiscal oversight, and complaint adjudication systems to back it up. As one example, the Minneapolis public school district is required to spend as of the latest report $43 million more on special education than the state reimburses. To cover this deficit, Minneapolise must divert funds from programs and services for other students. Under the Minnesota Supreme Court's Skeen decision the state is required to provide districts with enough funding to provide an adequate education meeeting state standards For students with disabilities districts are required to deliver the adequate education, but even for special education students the funding requirement is ignored.

Students in Early Childhood

Research is overwhelming that early childhood education — particularly for children facing educational barriers — produces substantial returns. The Great Start for All Minnesota Children Task Force, authorized by Governor Walz in 2021 with bipartisan support, recommended that Minnesota move toward a system where no family pays more than 7% of annual income on early care and education, and that early learning scholarships be expanded to include three-year-olds. Early investment reduces the remediation costs that accumulate when children arrive at kindergarten significantly behind. In 2024, first Children’s Finance estimated early childhood shortages affected 89,528 Minnesotan children with working parents. Without better options, many parents stay home or reduce their work to part-time in order to care for their children. Some parents alternate working hours with their partners or other family members, missing out on important family bonding time.

What the Research Says About Funding Weights

The 2004 Taxpayers Association study found that the cost of an adequate education in Minnesota varied from roughly $6,200 to over $14,000 per student — a ratio of more than two to one, depending on student characteristics. That study was conservative and is now more than two decades old. More recent research suggests the differentials may be even larger.

Dr. Bruce Baker's national research finds, as a general principle, that input-based analyses — which is what Minnesota's current categorical supplements essentially are — "fail to capture the full additional costs to provide equal opportunity in high need settings." In other words, the supplements Minnesota currently provides are structurally likely to underestimate what high-need students actually require.

What this means in practice: A school district in which 80% of students qualify for free and reduced-price meals, 30% are English Learners, and 15% have disabilities genuinely needs two to three times as much per-pupil revenue as a district serving a predominantly affluent, native English-speaking population. Minnesota's current formula does not come close to reflecting that differential. The districts serving the most vulnerable students are receiving the least adequate funding.

The St. Cloud Example

In 2023, the St. Cloud Area School District — in partnership with a citizen group called SCERAC — prepared a detailed description of what adequate funding would make possible for its students. The district's submission to MDE described specific programs that additional revenue would support, including: expansion of early childhood education; significantly enhanced Multilingual Learning services; expansion of its dyslexia programming; increased counseling and support staff; diversification of accelerated learning opportunities; and continued recruitment of teachers and staff of color.

The district noted with pride its commitment to evidence-based Multilingual programming — and documented the "multi-million dollar funding shortfall" that prevents it from fully implementing what it knows works. This is the practical consequence of inadequate weighted funding: schools that know what to do, and want to do it, but lack the resources.

The Principle: Fund the Actual Cost

The 2004 Governor's Task Force stated the principle clearly and it has not changed: "Education funding must be tailored to relevant characteristics of each individual student, such as student disabilities, household or neighborhood poverty, pre-K or Kindergarten readiness, and the needs of English language learners."

Twenty years later, Minnesota has still not implemented this principle in any rigorous way. Categorical supplements exist, but they are set by political negotiation rather than cost analysis. The adequacy study described in the previous post would provide the factual foundation for setting those weights correctly — based on what education actually costs for each student population, not on what the Legislature finds politically comfortable.

Funding the actual cost of education is not a luxury. Under Minnesota's proficiency-based standards, it is a legal and moral obligation.

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Next in the series → Post 5 of 8

Evidence-Based Practices: Money Is Necessary But Not Sufficient — Adequate funding is essential, but money spent on the wrong things doesn't help students. The next post explores how states like Illinois, Wyoming, and Maryland have paired funding reform with requirements to use evidence-based instructional practices — and why Minnesota's own Read Act offers a promising model for what this can look like statewide.