In Board of Educ. Levittown Union Free School Dist. v. Nyquist, (57 NY2d 27, 439 NE2d 359, 453 NYS2d 643 (1982)), plaintiffs, who included "property- poor" school districts, challenged the constitutionality of the state's system of financing public schools by which funds raised by locally imposed taxes are augmented by allocations of state moneys in accordance with a variety of formulas and grants. Plaintiffs claimed that the system violated the equal protection clauses of both the State and the Federal Constitutions and the Education Article of the State Constitution because it resulted in grossly disparate financial support and thus grossly disparate educational opportunities in the school districts, and further, that "property-rich" districts have an ability to raise greater local tax revenue enabling them to provide enriched educational programs beyond the fiscal ability of the "property-poor" districts. The Court dismissed the equal protection claims, noting that the same arguments were considered and rejected by the Supreme Court of the United States in San Antonio School Dist. v. Rodriguez, 411 US 1, 93 S Ct 1278, 36 L Ed 2d 16 (1973). "Noting that the subject of public school finance involves decisions both with respect to the raising and disposition of public revenues and of persistent, complex, and difficult questions of educational policy areas appropriately within legislative determination, the Supreme Court held that rational basis, rather than strict scrutiny, was the proper standard against which to examine the Texas public school financing system there under review (which was described by the court as 'comparable to the systems employed in virtually every other State' at pp 47-48). Applying this standard, the court found in the Texas system a rational relationship to a legitimate State purpose--the permission and encouragement of participation in and control of public schools at the local district level." (Levittown at 41.) In terms of a state equal protection claim, the Court noted that its prior decision in Matter of Levy, (38 NY2d 653, 345 NE2d 556, 382 NYS2d 13 1976) was controlling, wherein the Court held that rational basis was the proper standard for review when the challenged State action implicated the right to free, public education. Further, under a rational basis test, the Court held that "there has not been such a showing, and that the justification offered by the State--the preservation and promotion of local control of education--is both a legitimate State interest and one to which the present financing system is reasonably related." (Levittown at 44.) The Court noted that "it is the willingness of the taxpayers of many districts to pay for and to provide enriched educational services and facilities beyond what the basic per pupil expenditure figures will permit that creates differentials in services and facilities." (Id. at 45.) Further, the Court noted that "any legislative attempt to make uniform and undeviating the educational opportunities offered by the several hundred local school districts . . . would inevitably work the demise of the local control of education available to students in individual districts." (Id. at 45-46.) With respect to the Education Article, the Court noted that the constitutional language made no reference to any requirement that the education to be made available be equal or substantially equivalent in every district. The Court noted that "the Legislature has made prescriptions (or in some instances provided means by which prescriptions may be made) with reference to the minimum number of days of school attendance, required courses, textbooks, qualifications of teachers and of certain nonteaching personnel, pupil transportation, and other matters. If what is made available by this system (which is what is to be maintained and supported) may properly be said to constitute an education, the constitutional mandate is satisfied." (Id. at 48.) The Court noted that plaintiffs did not claim that "the educational facilities or services provided in the school districts that they represent fall below the State-wide minimum standard of educational quality and quantity fixed by the Board of Regents; their attack is directed at the existing disparities in financial resources which lead to educational unevenness above that minimum standard." (Id. at 38.) The Court found that the constitutional requirement of a "sound basic education" had been met, as the plaintiffs failed to establish any "gross and glaring inadequacy" "in consequence of the present school financing system." (Id. at 48-49.)