Our current conceptions of educational adequacy emerged out of an era dominated by equity-based school resource litigation. During that time of transitioning between successful litigation strategies, legal opinions provided clues as to how future courts might view a norm-referenced approach to establishing an adequacy standard--an approach that appreciates that for certain social goods, equity and adequacy are inextricably connected. This article explores three decades of school finance litigation and attempts to define the limits of the right to an education, to glean how a norm referenced right to education argument grows out of the historical legal framework.