own school tax rate, while the state supplied aid sufficient to provide each district with the revenues it would have reaped from its chosen tax rate had its property wealth equalized 135 percent of the statewide average property wealth per student" (Enrich, 1995:132). This suggests that the legislature understood the principle of fiscal neutrality used by the court. At the same time, however, the revised school law also established a mechanism for the state to adopt education standards and monitor students' success in meeting those standards.

When these reforms reached the New Jersey Supreme Court they were found to have brought the state into compliance (Robinson V, 355 A.2d 129, 1976). But this time, the majority and concurring opinion focused more on the substantive education goals and opportunities outlined in the new legislation than on the finance provisions. To the extent that the finance provisions were addressed at all, the inquiry was whether they would afford sufficient financial support for the education system, not on inter-district inequities. Put differently, the structure of this 1976 New Jersey decision was to look first to the quality of educational opportunities as a constitutional requirement, and then back into finance as a means of assuring that all students have access to those opportunities.

Litigation in New Jersey during the late 1980s and 1990s has incorporated both the educational opportunity strand and the strict dollar equalization strand of the Robinson era decisions. The Abbott v. Burke litigation, filed on behalf of a group of the state's poorest urban school systems, has made several trips to the New Jersey Supreme Court over the last decade. Two results have emerged. First, the court has required that the state equalize the spending in the poorest districts to that of the wealthiest districts. Second, the court has also required that the state provide additional funding to the poorer districts to account for the extra educational needs of children from disadvantaged backgrounds (Abbott, 643 A.2d 575, 1994). The court's most recent decision in 1998 (Abbott v. Burke, N.J. Sup. Ct. May 1998) moves further in the direction of constitutionally required educational quality, directing the state to implement a broad-based education reform package. Interestingly, those sweeping reforms were largely recommended to the lower court by the State Commissioner of Education. Now that they have been incorporated into the state supreme court's order, they take on the force of law and will bind the state government. At long last, after more than two decades of litigation, the New Jersey battle over school finance equity appears to be over.

Washington and West Virginia

While fiscal neutrality (the Coons team's Proposition I) dominated the school finance literature and the scholarly and policy debates of the early 1970s, two other state court decisions moved toward a different notion of equity during this same period. This notion might be called equity in access to adequate educational opportunities. Those two decisions established the conceptual precursor for today's educational adequacy movement. Adequacy broadens the notion of



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