Paynter v. State of New York

In Paynter v. State of New York (100 N.Y.2d 434, 441, 797 N.E.2d 1225, 765 N.Y.S.2d 819 [2003]), the Court held that "allegations of academic failure alone, without allegations that the State somehow fails in its obligation to provide minimally acceptable educational services, are insufficient to state a cause of action under the Education Article." In Paynter, the plaintiffs conceded that the State had sufficiently funded the Rochester City School District, but faulted the State for alleged "practices and policies that have resulted in high concentrations of racial minorities and poverty in the school district, leading to abysmal student performance" (100 N.Y.2d at 438). Although they did not claim any inadequacy of inputs, the Paynter plaintiffs maintained that the State had nevertheless failed in its obligation to provide a sound basic education by neglecting to mitigate demographic factors that may affect student performance. In their view, "no matter how well the State funds their schools, if plaintiffs and their classmates fail, it is the State's responsibility to change the school population until the results improve" (100 N.Y.2d at 441).