In Maryland, a twenty-minute drive separates students who will receive some of the best public education in the country and students who will receive some of the worst. For decades, students in Baltimore City have endured the conditions of a deteriorating public school system that is deficient in resources and infrastructure, while students in neighboring counties enjoy an abundant education. Maryland’s Constitution guarantees all students in the state a “thorough and efficient” education, regardless of the affluence of their neighborhood. The disparate quality of Baltimore City education was the subject of multiple bouts of litigation beginning in the 1980s and culminating in 2024, when the Maryland Court of Appeals dissolved a 1996 Consent Decree reached by the State and plaintiffs in Bradford v. Maryland State Board of Education to bring Baltimore City schools into constitutional compliance. Throughout nearly four decades of litigation, Maryland courts oscillated between interpretations of the “thorough and efficient” education required by the state constitution. Even after years of judicial oversight and mandated funding increases, the conditions of Baltimore City schools remain abysmal.

This Note argues that the 2024 dissolution of the 1996 Consent Decree was wrongly decided because the principal objective of the Decree—curing the constitutional defect present in Baltimore City schools—has not been met. Further, the “thorough and efficient” mandate in Maryland’s Constitution requires more than a neglected, slipshod education; Baltimore City students are entitled to an adequate education measured by contemporary criteria. The Note proposes a number of solutions looking forward to protect the educational rights of students in Baltimore City.