 In the context of school finance litigation in the US, advocates often invoke these two distributive ideals together rather than regarding them as being at odds (Rebell 2009: 21–22; Ryan 2008: 1232–1238). Although most school finance litigation in the US today is pursued from an adequacy framework given its greater political viability, litigators often make comparative claims about students’ educational opportunities to bolster their case. Conversely in contexts where lawyers pursue equality claims, they frequently appeal to a conception of educational quality (e.g., achieving literacy, numeracy, and civic skills) to anchor their claims, and to avoid the leveling-down problem whereby equality is achieved by making everyone worse off, without regard for the realization of particular educational goals.