Reply of Respondents to Petitioner's Response to this Court's Order of December 2, 1983

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National Headquarters 
Legal Department 

132 W. 43rd Street 
New York, NY 10036 

Phone: (212) 944-9800 

AMERICAN 
CIVIL 
LIBERTIES 
UNION FAX: (212) 730-4652 

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Privileged and Confidencial 

Font 

  

National Haadguartars 

ey 132 Wasat 43 Strast 
Naw York, NY 10038 
(212) 944-8800 

Nadine Strassen 
PRESIDENT 

ire Glasser 
EXECUTIVE DIRECTOR 

November 22, 1991 Richard Zacks 
TREASURER 

  

Helen Harghhkolf 
Atte rey Work Product ASSOCIATE LEGAL DIRECTOR 

Professor John Brittain 
University of Connecticut 

School of Law 
65 Elizabeth St. 
Hartford, CT 06105 

Ronald Ellis 
Marianne Lado 
NAACP Legal Defense and 

Educational Fund, Inc. 
99 Hudson St. 

New York, NY 10013 

Weasley W. Horton 
Moller, Horton & Fineberyq 
20 Gillett St. 
Hartford, CT 06105 

Re: Sheff v. O'Neill 

Dear Colleagues: 

Wilfred Rodriguez 
Hispanic Advisory Project 
Neighborhood Legal Servicas 
12292 Albany Ave. 
Hartford, CT 06112 

Martha Stone 

Philip Tegeler 
Connecticut CLU 
32 Grand Street 
Hartford, CT 06106 

Jenny Rivera 
Puerto Rican Legal Defense 

and Educational Fund, Inc. 
299 Hudizon St. 
New York, NY 1.0013 

As you know, Adam Cohen, Philip Tegeler and Helen Hershkoff 
met with Professor Gary Natrilelleo of Teachers College last month 
to discuss the possibility of his preparing an analysis of dis- 
trict resources and disparities in Hartford and the surrounding 
suburbs. We asked Professor Natriello to prepare an outline of 
his proposed study. I am enclosing for your comments Professor 
Natriello's proposal. 

Ag you will see from the attached letter, we have promised 
to get back to Professor Natriello by mid-December with the 
team's comments about the proposal. Would it be possible to have 
a conference call about the proposal sometime during the week of 
Dacember 27? Eric Jennings, Helen's assistant, will call each of 
you Thanksgiving week to get a sense of your availability. 

MOL ZB.) LES] PAGE . ABE 

 



  

csheff Litigation Team 41a 45 

November 22, 1991 
™ o 
rage 2 

Thank you for your cooperation. 

LJ a ¥2 wan) RF RFT R : Very truly youre, 

Adam S. Cohen 

Staff Attornay 

Enclosures 

 



  NOL 

II 

  

TEACHERS COLLEGE COLUMBIA UNIVERSITY 

NEW YORK, NEW YORK 10027 

Program in Sociology and Education 

1 November 1991] 

Helen Herskoff 
American Civil Liberties Union Foundation 
132 West 43 Street 
New York, New York 10036 

Dear Helen: 

! have enclosed a first draft of a scope of work statement for a set of modules for the 
study of district resources and disparities in Hartford. Once you have had time to 
roadee this draft, we can discuss the revisions ne cessary to make sure that it responds 
to your needs. I look forward to your reactions to this initial draft, 

Sincerely, 

ciate Professor 
ciology and Education 

 



    

» Fin 

  

Proposed Scope of Work to be Performed by Gary Natriello for the 

Study of District Resources and Disparities in Hartford 
Draft - November 11, 1991 

The work for this study of district resources and disparities can be divided into four 

modules of approximately equal effort. Although each module contains related aspects 

of the project, it is possible to reorganize the modules to achieve a configuration that 

best suits your needs. The strongest approach might be to consider each of these 

modules as part of a single comprehensive study and report. 

Module 1 - Documenting the Basic Needs of the Hartford District 

This component will focus on the population of students and families served by 

the Hartford School District. Work will begin with an examination of the available 

data that can be used to characterize the population, Where possible an attempt will be 

made to move beyond data aggregated to the city level to data on children of school age 

and their families. Key indicators such as race/ethnicity, poverty status, LEP status, 

family composition, mobility, health problems, academic performance, social and 

emotional development, housing situation, and community isolation will be considered. 

Moving beyond the data that are widely available, data wil be requested from the 

school district's own records. In addition, a small number of interviews will be 

conducted with those school personnel most aware of the needs of students and their 

families. The interviews will be designed to move beyonc the available data to produce 

a first-hand view of the needs of Hartford students. Both special needs students and 

non-special needs students will be described. 

The goal of this section of the report is to determine just how unique the needs 

of Hartford students are. To the extent that student needs are unique in character or 

severity, they may suggest that cross-district comparisons of educational resources are 

inappropriate. In light of the less than dramatic nature of many of the cross district 

contrasts in the state reported data, a careful description of the problems of the student 

population will be helpful in making the case that simple comparisons fail to portray 

the comparative disadvantage of the Hartford school district. 

Module 2 - Documenting the Resources of the Hartford District 

This component will detail the resources of the Hartford school district in 

financial and programmatic terms. The sources of financial support will be examined 

to determine the family, community, local, state, federal ind other contributions. 

Beyond the standard calculations of tax monies available to the district, attention will 

be directed to the level of financial contributions that might or might not be made by 

families (e.g., PTAs, Booster Clubs, support for student supplies, etc.), and 

communities (e.g., business assistance). An aspect of the analysis of the resources of 

families and communities will be an implicit comparison with what might be expected 

in suburban districts. av 0 

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The examination of the major governmental sources of support is rather 

straightforward, but essential if we are to understand the role of the state financial 

arrangements in contributing to the educational disadvantages experienced by students 

in the Hartford schools. More important than the sources of financial resources is 

charting the flows of those resources to major groups of students. The most important 

group distinction apparent at this point is that between special needs students and non- 

special needs students, since the latter seem to be particularly disadvantaged in light of 

= limited resources available to them once their share of district resources is 

disaggregated. However, there may be other special populations that are particularly ill 

served by the present financial arrangements, 

Tracking the flows of financial resources within the district will quite naturally 

lead to an examination of the program offered by the district, In addition to resources 

devoted to special programs, it will be important to understand the level of support 

available for the regular school program, including things such as supplies and 

materials, certificated teaching staff, educational support personnel, social services 

personnel, and other service personnel. Important distinctions to be examined are those 

among the level of resources devoted exclusively to instructional or educational 

purposes, the level of resources devoted to dealing with an ii pg infrastructure 

(e.g., buildings, maintenance), and the level of resources devoted to dealing with social 

problems not directly related to education (e.g., family and community disadvantages). 

Obviously, educational expenditures may look quite similar in aggregate calculations 

and appear quite different once we remove the resources devoted to non-education, but 

essential, services. 

Although some perspective on the issue of district resources may be gained from 

the available documentation, much of the information for this section of the report will 

rely upon interviews with central administration personnel, including special program 

managers, in the Hartford district. A good deal of the effort involved here will be in 

translating the fiscal information routinely kept by the district into the programmatically 

important categories that form the heart of this section. 

This section of the report will present a portrait of the program offered by the 
Hartford district to meet student needs. Attention will be devoted to the access of 
students to basic educational resources with special emphasis on the proportion of the 

population with needs that are not being addressed by district services. 

A component of this section will examine the impact of the less than adequate 

district resources on the instructional program and ultimately on students. Attention 

will be devoted to the development of school cultures dominated by low expectations 

that have been reported in the Hartford District. Student and staff attrition will be 

examined as indicators of an environment hostile to human growth and development. 

Module 3 - Documenting the Comparative Disadvantage of the Hartford District 

This component will make explicit what the work in the other modules can only 

imply, that is, the relatively disadvan:aged position of the Hartford schools. The work 

will proceed in three stages. First, available data on district resources and programs 

for all districts in the state of Connecticut will be examined to establish Hartford's 

position in the state. Second, available data on resources and programs will be 

examined for the set of six districts adjacent to Eartford, Third, interviews will be 

conducted in one district adjacent to Hartford to provide the details for a portrait of the 

stark differences between the educational experiences of Hartford students and those in 

MO. 28 Yel ol Bas 3 FAGE . AE . 
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the other district. We will need to discuss the appropriate district for this detailed 
comparison and the means of gaining access to personnel and data from that district, 
Key points of comparison will include student characteristics and needs, financial and 
programmatic resources, the access of students to resources, and the outcomes in terms 
of student achievement and attainment. 

Module 4 - Documenting the Absolute Disadvantage of th: Hartford District 

The purpose of this section is to move beyond the relative standard of 
educational adequacy defined in terms of comparisons with other districts to a new 
standard of educational adequacy defined in terms of the basic educational and other 
services required by disadvantaged students if they are to achieve relatively productive 
adult lives. To the best of my knowledge, this has not been done. 

Three strategies can be used to begin to define such standards of educational 
adequacy. First, internal comparisons can be made among groups of students in the 
Hartford district. This strategy will entail identifying students with similar problems, 
only some of whom are being served by the district. If wz can determine that the 
services provided to some students are effective in enhancing their experience in the 
district while students denied such services suffer in comparison, then we might 
conclude that such services meet minimal standards of adequacy necessary for all 
students in the district. Second, we can examine the stancards for educational 
programs and services established by Connecticut to determine those areas in which the 
Hartford district is unable to meet such standards. Third, we can examine the 
standards for educational programs and services established by other agencies, 
including various accrediting agencies, and experts in the field also to determine those 
areas in which Hartford is unable to meet the standards, 

The analyses proposed for this module will require the review of state and 
national standards in a variety of areas as well as interviews with key personnel in the 
Hartford district. The report on this section will focus on developing a description of 
adequate educational services for at-risk students and then comparing that portrait with 
what the Hartford district is currently able to offer. 

Costs 

I would estimate the total costs for a detailed study including all four of these 
modules at $40,000. Since I have tried to create modules of equal effort, each 
individual module will cost $10,000. If these costs are beyond your budget, I would 
advise cutting one or more modules rather than reducing the level of work across-the- 
board, I would view modules | and 2 as essentizl for the position you are trying to 
establish in the case. Having sketched out the elements of the project, I am somewhat 
concerned about the schedule we discussed. You may want to consider moving ahead 
with the first and second modules and only after they are complete, considering 
whether to move ahead with the third and/or fourth modules.