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.
