|
AN EXAMINATION OF THE EFFECTS OF LOCAL SCHOOL DISTRICT
DISCRETIONARY LEVIES ON THE FISCAL EQUITY
OF A STATE FOUNDATION DISTRIBUTION SYSTEM
BY
JEFFREY
MAIDEN
A DISSERTATION PRESENTED TO THE GRADUATE SCHOOL
OF THE UNIVERSITY OF FLORIDA IN PARTIAL FULFILLMENT
OF THE REQUIREMENTS FOR THE DEGREE OF
DOCTOR OF PHILOSOPHY
Dedicated
to the memory of my stepfather,
John Robert Snyder.
ACKNOWLEDGEMENTS
express
deep
appreciation
Lord
Savior
Jesus
Christ.
thank
unlimited,
match
ess
grace,
providing
eternal
salvation
human
race
, and
making
this
dissertation
possible
support
guidance
committee
chair
, Dr
Craig
Wood,
een
invaluable
He has
been
mentor
teacher
over
last
four
years
, and
could
never
express
true
apprec
nation
what
done.
Thanks
Honeyman.
also
Through
committee
Dr. Honeyman
cochair
have
, Dr. David
acquired
appreciation
school
finance
data
analy
S1S
as well
as the
proper
perspecti
never
taking
"stuff"
seriously
Acknowledgement
goes
to Dr
David
Miller
from
whom
have
developed
an appreciation,
respect,
fascination
research
data
analysis
educational
measurement.
Further
acknowledgement
goes
to Dr
Linda
Crocker
providing
opportunity
acquire
coll
teaching
experience.
Thanks
to Dr
. James
Hensel
always
being
available
support
and
direction
dissertation
writing
process
Last
appreciation
to both
encouragement
least
parents
during
this
would
like
stepparents.
entire
process
to express
Their
my deep
support
been
crucial.
TABLE OF CONTENTS
ACKNOWLED GEMENTS .................. .. .. .. ..... .. i11
ABSTRACT .. .. .. .. ........ ... .... .. ... .... ....vil
CHAPTER 1 INTRODUCTION ..... ................ .. .. ... 1
Purpose of the Study.......
Research Question...........
Significance of the Study...
Limitations.. ...
Delimitations...............
Overview of the Methodology.
Design of the Study ........
NoPTER 2 REVIEW OF THE LITERAL.
PTER 2 REVIEW OF THE LITERA
.. .. .. .. .. .. .. .. 6
.. .. .. .. .. .. .. .. 8
..............................38
The Theory of Per-pupil Funding Equity.
School Finance Equity Court Cases......
Foundation Method of Financing Schools.
Previous Florida School Finance Equity
Conclusion .... ...... .. .............
Notes .......... ... ..... .. .. .. .........
Population..
FEFP .
Design......
Measurement.
Conclusion..
Notes .
.. ..............12
.... ............ 20
. .. .. ....... .. 43
Studies. .........51
S. ......... 64
. .. .77
......................................... 80
. .. .. 89
.. .. .. . .92
. ....................... t110
. f . ft. t t t t t t t f f 111
Resource Accessibility.
S .. .. 118
CHI
CHAPTER 4 RESULTS ... .................. .. .. ...117
_____~
-- ~ w -- _1 -- T .w w wi i
TURE .. .. .. .. .. ....11
CHAPTER 3 METHOD ... ........ .. .. ..77
Summary. ....
Observations..
Conclusions...
Implications..
Notes ..
APPENDIX A FEFI
APPENDIX B RAW
BIOGRAPHICAL SKETCH
S. . 135
S. S . .137
S. . 141
S. . 143
. ...... ... ..146
? COST FACTORS .. ....... ........... .. .. 147
DATA .... .. .. .. ....... 148
. . 157
CHAPTER 5 DISCUSSION. .. .. .. .. .... 13
LIST OF REFERENCES .. ................. ................... .. 151
Abstract
Dissertation
the University
Requirements fi
Presented
Florida
to the
in Partial
Degree
Doctor
Graduate
School
Fulfillment
Philosophy
AN EXAMINATION
OF THE
DISCRETIONARY
OF A STATE
EFFECTS
LEVIES
FOUNDATION
OF LOCAL
ON THE
FISCAL
DISTRIBUTION
SCHOOL
DISTRICT
EQUITY
SYSTEM
Jeffrey
August,
Maiden
1994
Chairman:
Cochair:
Major
Craig
David
Department
Wood
. Honeyman
: Educational
Leadership
This
disequalizing
quantitative
effects
study
was
local
designed
school
examine
district
discretionary
levies
when
applied
to a foundation
system
education
finance.
1992
data
Florida
used
Education
study
Finance
were
Program,
obtained
which
from
included
equalized
foundation
component
separate
discretionary
revenue
sources.
These
discretionary
sources
, the
current
operation
discretionary
levies
capital
outlay
and
maintenance
levies
, were
based
entirely
on property
taxation
yield.
Resource
accessibility
measures
indicated
increasing
variability
distribution
resources
discretionary
revenues
from
either
sources
were
added
to foundation
revenues.
capital
outlay
maintenance 1
accessibility
evies
contributed
variation
than
more
to the
current
resource
operation
discretionary
levies.
addition
discretionary
revenues
from
each
source
demonstrated
neutrality
noteworthy
disequali
distribution
zing
system.
effect
The
on the
wealth
effects
capital
outlay
and
maintenance
revenues
were
more
acute
than
effects
current
operation
discretionary
revenues.
Both
discretionary
equivalence
revenue
yield
when
sources
combined
decreased
with
level
foundation
revenue
source
The
capital
outlay
maintenance
source
more
disequalizing
effects
in the
realm
taxpayer
equity
than
current
operation
discretionary
source.
Replications
current
study
in states
with
similar
systems
education
finance
are
warranted.
Additionally,
studies
into
fiscal
equity
effects
as well
as the
costs
incorporating
statewide
equalization
programs
discretionary
levies
are
recommended.
CHAPTER
INTRODUCTION
Fiscal
equity
as it relates
to financing
schools
rich
tradition
education
finance
literature.
Broadly
defined,
fiscal
equity
school
finance
refers
condition
fair
a given state
education give
broad
treatment
should
n their
nature
provided
varying
theory
students,
equivalent
educational
fiscal
that
support
needs
equity,
students
for
Because
best
understood
following
fisc
this
divided
section
equity
study p
includes
through
provides
defined
a short
analysis
more co
various
components.
description
mplete
components.
discussion
theory
Chapter
the
development
theory
equity
realm
financing
education.
Fiscal
degree
equity
equity
is most
among
commonly
groups,
discussed
students
terms
taxpayers.
Equity
among
students
a reference
to the
basic
fairness
distribution
educational
resources
among
students.
Most
per-pupil
equity
studies
include
examination
equity
0 l-* A-
a --
A~C~~Uf 0
1_ I -
t-^ Y.*
, f, ^ l
Horizontal
equity
refers
an equal
treatment
equals.
A horizontally
equitable
condition
is one
which
equal
resources
are
available
to pupils
with
equal
needs
Vertical
equity,
conversely
,refers
to unequal
treatment
unequal s
varying
these
Because
levels
needs.
students
resources
Under
have
varying
per-pupil
concept
are
vertical
educational
necessary
equity
needs,
to meet
such
differences
are
taken
into
account
Wealth
neutrality
support
wealth
neutrality,
or equality
education
state,
alternatively
known
opportunity,
students
local
fiscal
degree
related
community
to which
to the
which
they
are
educated.
A wealth
neutral
condition
one
which
fiscal
support
students
is not
related
to the
fiscal
conditions
local
school
districts
Taxpayer
equity
refers
to the
basic
fairness
among
taxpayers
a state
in terms
their
support
education.
Taxpayer
equity
exists
to the
extent
that
equal
effort
support
education
results
equal
resources
per-pupil
Education
finance
researchers
have
also
been
interested
other
theoretical
considerations
school
funding
systems.
Most
common
are
adequacy,
efficiency,
exce
llence.
Adequacy
a reference
to whether
students
n^ -. r-'f
-~~n -LL a 4--Lt -- A1
1 a
L
^
f
L .
ft r ^
fairness,
adequacy
stresses
acceptability
level
support
throughout
distribution.
Excellence
degree
refers
educational
to the
quality
concept
In the
attainment
school
a high
finance
context,
such
excellence
quality.
implies
Efficiency,
fiscal
on the
support
other h<
sufficient
and,
to fund
as a finance
construct
resources
significant
implies
Thouc
constr
maximizing
;h adequacy,
ucts worthy
educational
excellence,
further
output
and
given
minimum
efficiency
research,
equity
are
has
a longer
history
as a school
finance
theory
generated
a tremendous
number
individual
studies.
Purpose
Studv
A foundation
system
school
funding
pertinent
context
provides
state
fiscal
funding
a minimally
equity
to guarantee
acceptable
that
each
level
system
every
theoretically
child
education.
Because
each
child
is guarant
this
foundational
level
funding,
theory
equality
educational
opportunity
provided
through
distribution
system.
Yet,
despite
this
recognition
states
to take
an active
funding
role
order
to equalize
to a minimally
acceptable
level
children,
foundation
system
typically
include
allowing
local
stricts
4- a 1 A- -A--S
1 -
,II,,,
t
L
funding
assure
each
child
a minimally
acceptable
level
education,
represented
foundation
funding
level,
allows
districts
discretion
raise
funds
beyond
this
minimum.
Because
a foundation
funding
plan
designed
to promote
equity,
are
tension
permitted.
results
Thus
when
unequalized
, discretionary
millage
discretionary
rates
levies
and
resultant
levies
are
problematic
sense
equity.
According
to Wood
Thompson,
The problem i
leeway, the s
foundation.
discretionary
first sought
not to permit
is once
unaided
again
perplexing.
cheme
would
state
village, it
to eliminate.
discretionary
thwarted. Th
discretionary
state
no longer
fails
equalized
local
a minimum
to equalize
restores
Further, if
millage, the
basic fact
counters
village
inequality
state
minimum
is that
it
did
concept
any
equalization,
while
only
denying
other
loca
option
scretionary
solution
1 leeway violate
is to limit the
village,
is only
minimum
intent
amount
clear
that
a compromise
According
to Thompson,
Wood,
Honeyman,
three
problems
related
to equity
emerge
districts
are
permitted
to levy
discretionary
dollars
to supplement
a minimum
foundation
program.
First,
basic
foundation
program
does
include
provisions
equalization
funds
derived
from
millage
rates
above
minimum
foundation
level.
Second,
distri
must
send
less
'AA.'.
discretionary
millaae
^f
_L_ L_
problem
related
to the
inclusion
discretionary
levies
minimum
foundation
program.
Research
Question
research
question
addressed
this
study
was,
state
with
a foundation
program
support
schools
including
one
or more
discretionary
millage
rates,
to what
extent
levies
resulting
from
application
discretionary
millage
rates
introduce
inequities
into
system
distributing
education
funding?"
Significance
the
Study
study
theory
was
per-pupil
intended
fiscal
to make
equity,
a contribution
which
to the
rich
school f
research
finance
activi
literature
ty among s
focus
school
finance
a great
scholars.
The
deal
study
was
local
intended
school
possible
to provide
districts
education
insight
to strive
children
to the
for p
within
problem
providing
allowing
best
parameters
distribution
formula
while
maintaining
fiscal
fairness
throughout
a state.
foundation
program
is by
most
popular
method
financing
public
education.
Currently
, thirty-eight
rI ,,
r 1.1
foundation
system
state
Florida
was
chosen
this
study.
Florida
is one
most
populous
states
nation
serves
one
largest
public
school
enrollments.
This
study
was
intended
to provide
examination
public
school
system
Florida,
with
particular
attention
to its
funding
methodology.
Limitations
current
study
was
limited
to the
theory
equity,
without
assessments
adequacy,
effic
iency,
or excellence.
Equity
equity,
assessments
wealth
were
limited
neutrality,
to horizontal
taxpayer
equity.
per-pupil
Vertical
equity
was
addressed.
A macroanalysis
a state
system
distributing
education
resources
was
included
study,
microanalysis.
Assessments
equity
distribution
resources
among
districts
were
made.
No effort
was
made
examine
distribution
within
districts.
Delimitations
Data
fiscal
were
year,
taken
1992
from
-93,
one
most
state
recent
included
in which
only
data
one
were
available.
Fiscal
data
were
additionally
limited
to those
- ,
r --
- .
C~,
4 *
study
secondary
examined
schools o
fiscal
nly.
data
Neither
from
public
private
elementary
schools
nor
higher
education
organizations
were
considered.
Overview
Methodoloav
foundation
distribution
system
state
Florida
was
used
study.
Data
study
were
taken
from
Florida
Education
Finance
Program
(FEFP)
1992-93
school
Year.
FEFP
included
a foundation
basic
support
program
in addition
to two
unequalized
discretionary
village
rates,
discretionary
millage
capital
outlay
among
maintenance
districts
millage.
derived
Mean
from
per-pupil
foundation
revenues
program,
discretionary
levies,
capital
outlay
maintenance
levies
were
used
to analyze
equity
FEFP
distribution.
per-pupil
revenues
were
divided
into
seven
levels
aggregation
which
included
combinations
foundation,
discretionary,
capital
outlay
and
maintenance
revenues.
Equity
was
measured
according
to three
standards.
first
was
resource
accessibility,
which
provided
assessment
-pupil
horizontal
equity.
second
was
wealth
neutrality
, using
per-pupil
assess
valuation
as the
1-"n C.
et C 1
r a a
- -A -
m L -
f-*r
iLt -; _-3
_ -
*..
following
section
includes
a summary
contents
study.
Design
of the
Study
Chapter
provided
an introduction
to the
study.
nature
problem
was
presented
as well
as the
specific
research
significance
delimitations
and
question
study
addressed.
as well
an overview
Following
was
limitations
methodology.
the
and
Chapter
presents
a review
literature
pertinent
to the
study.
This
includes
a description
historical
development
theory
fiscal
equity
as well
as a summary
court
cases
was 1
through
egally
which
tested.
the
The
equity
state
literature
foundation
review
further
systems
eludes
both
a written
description
of the
foundation
method
distributing
research
education
studies
dollar
concerning
a review
Florida
s foundation
previous
distribution
system.
Chapter
includes
a description
research
methodology
includes a
in greater
detail
discussion
than p
results
provided
above.
study
Chapter
while
Chapter
includes
a summary
as well
as conclusions
and
implications
derived
from
study.
2Thomas
York:
Burrup
Macmillan
, Vern Br
Jones,
Publishing
imley, Jr,
Introduction
Company,
and Rulon
to School
1985), 5;
Garfield,
Finance
(New
Percy
F inancina
Education
in a Climate
of Change,
(Boston:
Allyn
Bacon,
1988
Lawrence
, 79-80
Pierce,
James
. Guthrie,
ol Finance
Walter
Education
. Garms,
Policy:
Enhancing
(Englewood
Efficiency.
Cliffs
Eaualitv.
Choice
NJ: Prentice-Hall,
1988)
, 2nd
, 130;
David
Monk,
Educational
Finance:
An Economic
Anoroach
(New
York:
McGraw-Hill,
Education Fi
1990
-nance
35;
Law:
Craig
Wood
Constitutional
David
Challenges
. Thompson,
to State Aid
Plans--An
Analvsi
Strategies
(Topeka,
KS: National
Organization
C. Thompson,
Leadership f
NY: Longman
Legal
Craig
Schools
Publishing
Problems
Wood,
: Concerts
Group,
in Education,
David
1993)
Honeyman,
Practices
David
scal
(White
Plains,
1994
Berne
Leanna
Stiefel,
Measurement
Eauitv
in School
University
Guthrie,
McCarthy,
Secondary
Press
Finance
, 1984),
Garms, al
Stephen
Education
(Baltimore
13; Burrup
Pierce, 302
Thomas,
(Columbus
:Me
: The
Johns
, Brimley,
Dean
Hopkins
and
Webb,
Financing Elemen
rrill Publishing
Garfield,
Martha 1
tarv
, 1988),
Monk
Standards
Standards
Aid Progr
Wood
Re.
am,
and
Robert
State
levant to
" Journal
Thompson
Berne
School
Secti
Leann
Programs:
on 5(d) (2
of Education
, 18
; Thompson,
a Stiefel, "
Philosophies
Finance
Wood,
Equity
and
Federal
(Summer
Impact
, 1993),
Honeyman,
4Berne
Steifel,
Measurement
Eauity
, 13;
Burrup,
Pierce,
Berne
Brimley, a
302; Webb,
d Stiefel,
Thompson,
Wood
Garfield,
McCarthy,
"Equity S
, and
Guthrie
and
Thomas,
Standards,
" 95
, Garms,
189;
; Woo
Monk,
d and
and
37-39
Thompson,
Honeyman,
5Berne
Stiefel,
Measurement
Eauitv,
Burrup,
Thomas,
Brimley,
189;
Berne
Garfield,
d Stiefel
80-81;
, "Equity
Webb
, McCarthy
Standards,
, and
" 95
6Berne
and
Stiefel,
Measurement
Equity,
41-42
Guthrie,
Garms,
Pierce,
Webb,
McCarthy,
and
Thomas,
192;
Berne
Stiefel
, "Equity
Standards,
" 96-97
3Robert
8Guthrie
, Garms
Thoma
School
Longman,
, and
Austin
Finance
1991)
: Its2
, 225;
Pierce,
Swanson
Economics
Thompson
and
Wood
150-152
Webb,
Richard
Politics
, and
New
McCarthy
. King,
York:
Honeyman,
9Arthur
Stellar,
"Implications
Programmati
Excellence
The
Equity,
" in
Fiscal. Leaal.
Van
and
Mueller
Political
Mary
. McKeown
AsDects
Elementary
Secondary
Education
(Cambridge
, MA: Ballinger
1986);
Pierce
Burrup
, 29.
, Brimley
, and
Garfield,
Guthrie
, Garms
, and
10Burrup
, Brimley
, and
Garfi
eld,
Guthrie
, Garms
, and
Pierce
, 28-34;
Swanson
Webb
King
, 259
, McCarthy
, and
Thomas
, 192;
Monk
, 4-11;
-278.
1lBerne,
"Equity
Issues,
" 159
Andrea
United
Stephen
C. Hyary
States
Study
and
Canada.
States
David
Publi
Smith
School
1990-91
, Stephen
Finance
, vol.
B Lawton
, and
Proarams
Albany
Center
, 1992
13Wood
Thompson,
14Thompson,
15Gold,
Wood
Smith,
Lawton
Honeyman
, and
Hyrary,
-224
18.
. Gold,
(eds.),
, NY:
CHAPTER
REVIEW
OF THE
LITERATURE
In Chapter
research
question
addressed
this
study
was
presented.
Specifically,
this
study
dealt
with
effects
moneys
raised
through
local
discretionary
millage
rates
on fiscal
equity
a state
foundation
distribution
system.
This
chapter
includes
a summary
literature
related
to the
study.
The
chapter
begins
with
a summary
development
theory
of educational
funding
equity,
which
was
introduced
chapter
of this
study
to which
this
study
was
intended
to contribute.
Subsequently
discussion
turns
to d
decisions
rendered
federal
state
court
systems
dealing
with
problem
providing
equitable
systems
education
funding
states.
Following
this
summary
of relevant
court
cases
is a discussion
foundation
system
distributing
state
funds
to local
school
districts.
final
section
this
chapter
includes
a summary
previous
studi
equity
distribution
school
funds
through
foundation
system
Florida,
state
from
which
data
were
derived.
Theory
Per-Puoil
Funding
Eauity
nature,
providing
an equitable
system
funding
education
requires
state
to provide
greater
financial
support
to less
wealthy
local
education
agencies
because
such
stricts
have
access
to the
same
fiscal
resources
which
wealthier
district
have
access.
Following
discussion
historical
development
theory
equity
relates
to state
financial
support
public
education.
With
publication
monograph
1906,
Ellwood
Cubberley
was
first
modern
scholar
to discuss
concept
equity
relates
to school
finance.
Cubberley
was
first
to develop
concept
that
schools
a state
should
considered
a state
system
schools,
rather
than
series
local
systems,
in order
to foster
equitable
funding.
According
to equalize
resources
to Cubberley,
advantages
available
to all
to the
duty
school
state
state
children
Cubberley
was
considering
theorized
that
that
state
could
itself
generate
should
revenue
provide
fiscal
equivalent
to districts
to other
areas
state
in order
to equalize
educational
opportunity
throughout
state.
According
to Cubberley,
[A]id
should
needs
bear
some
community
definite
and
relationship
the efforts
-- _- 1 A-
* '
SI
S1 --
1
*1
t
K
1
l
_
guarantee
a certain
minimum,
or foundational,
level
funding
each
child.
In collaboration
with
Haig,
Strayer
argued
that
order
to achieve
equalization
educational
opportunity:
[I]t wo
schools
uld
or make
furnish
within
the
stat
opportunities
(2) to raise
purpose
such
manner
localities
their
adequa
control
direct
local
necessary
other a
children
e with e
D to som
ability;
to establi
arrangements
in every 1
qual
e
funds ne
or state
as to bear
at the same
sufficient
ocality
educational
prescribed
cessary r
taxation
upon
rate
tax-paying
tely either
school
admini
education.
station,
6
minimum
This
adjusted
the people
in relation
in all
to
to provide
supervision
, or for
a state
and
their
department
Strayer
envisioned
that
each
local
district
provide
a level
taxation
that
would
provide
funding
minimally
acceptable
level
education
applied
residents
wealthiest
wealthiest
district,
district
in applying
state.
this
rate,
would
raise
money
required
to finance
schools
within
strict
s borders.
The
state
would
grant
each
remaining
district
enough
money
that,
combination
with
funding
raised
locally,
supported
this
minimally
acceptable
level
education.
Strayer
held
that
same
local
tax
rate
should
exerted
throughout
state
In this
respect,
district
Strayer
citizens
believed
that
district
allowing
districts
so desired.
to generate
moneys
beyond
those
resulting
from
statewide
local
effort
rate
would
have
disequalizing
effects
Strayer
claimed
that
"logical
conclusion"
equalizing
educational
opportunity
was
a full
, statewide
system
schools.
administration
Yet,
being
localization
strongly
grounded
financing
American
tradition,
Strayer
maintained
that
some
degree
of local
control
should
maintained
a state
Harlan
Updegraff
, writing
early
1920s,
concurred
state
order
however,
with
should
to provide
that
early
poorer
equal
addition
proponents
districts
opportunity.
distri
equity
more
that
generously
Updegraff
should
argued,
rewarded
effort
sense
willingness
raise
educational
revenues
through
taxation.
Equalization
funding
from
state
, acc
ording
to Updegraff,
should
a function
effort
forth
each
district.
result
same
same
effort
level
from
fiscal
distri
support
would
education
funding
unit.
Updegraff
believed
that
such
a system
would
promote
A----~ ~ ~ ~ ~ -- I -A........
I
L. -
I_
A
- t ^ -
_ -
I
A ___ __ ^ I -
"1 -
.. 1
required
to exert
greater
effort
order
to provide
an acceptable
level
education.
Through
equalizing
system
that
rewards
effort,
state
would en
mandated
courage
localities
foundational
rise
level,
above
therefore
a certain
with
state
state
assistance
each
district
would
a position
best.
Henry
Morrison,
like
previously
mentioned
providing
researchers
equitable
supported
funding
theoretical
education,
ideal
took
concept
funding
a step
further
public
advocating
schools
Morrison
completee
believe
statewide
i funding
inequities
emanated
from
fundamental
flaw
existence
localized
funding
educational
enterprise.
Morrison
proposed
that
instead
providing
a system
distribution
state
funds
inverse
proportion
Strayer,
to local
a system
district
which d
needs,
districtt
as advocated
organization
bypa
ssed
should
come
into
fruition.
each
student
would
provided
an equivalent
level
funding
from
revenue
generated
through
state
taxation.
Under
American
ideal
federalism,
according
to Morrison,
states
* .,
maintained
plenary
, S
power
over
* .- ..
I
1
state
level
funding
circumventing
local
control
without
imparting
damage
on the
American
system
governance.
Morrison
argued
that
revenue
these
state
funds
could
come
from
among
four
sources
in any
combination.
These
included
property
taxes
levied
statewide
state
income
taxes
, state
taxes
on corporations,
income
from
state
school
lands
or invested
school
fund
Paul
College,
. Mort,
expanded
a student
concept
Strayer
initially
at Teacher
developed
Strayer
Haig
that
state
should
establish
and
help
support
a foundational
level
education
children.
Because
a foundational
level
education
should
based
on educational
need,
Mort
developed
idea
quantifying
educational
need
using
school
finance
policy.
According
to Mort
, the
educational
need
. of
composite
community
public
a community
of those
that
would
educational
offering
regarded
as the
element
cost
demanded
state pr
children
ogram
making
a satisfactory
opportunity.
element would
cost
available
minimum ed
relative
determined
weighting
to all
ucational
each
18
d
state.
Mort
referred
to this
method
as the
"satisfactory
equalization
program.
Mort
discussed
specific
planning
such
equalization
program.
ssroom,
expressed
teacher
units
, was
cost
unit
plan.
Basic
ally,
according
to Mort,
each
child
would
have
available
where
ssroom
a program
or teacher
of satisfactory
equipped
equal
point
zation
education
would
met.
Each
community,
in turn,
would
have
suffi
cient
classroom
units
to appropriately
educate
children
that
community.
concept
per-pupil
equity
specifically
relates
to the
foundational
state
distribution
system
was
developed
scholar
finance
career,
authors.
Mort
21 as
For
throughout
well as by
.I
example,
remainder
other
Edgar
notable
Morphet
school
discussed
important
elements
which
should
included
in a
worthwhile
granted an
foundation
adequate
program.
level
education,
children sh
financed
lould
jointly
state
respect
tive
local
districts.
system
should
promote
equality
educational
opportunity
among
students
state.
Local
districts
should
able
to fund
schools
above
S1 a a a
* *
* *
substantial
contribution
to the
foundational
level
order
that
no undue
burden
would
placed
on the
local
districts.
foundations
concept
equity
were
laid
these
scholars.
With
their
writings
theory
equity
relates
to education
funding
developed,
late
1960s
and
early
1970s
many
states
established
systems
which
state
made
corrections
existing
National
inequities.
Education
According
Foundation
to data
provided
Project,
late
1960s
forty-two
states
used
equalization
programs
fund
school
seven
states
employed
non-equalizing
flat
grant
distribution
systems,
one
state,
Hawaii,
used
a system
complete
state
federal
support.
Strayer-Haig
foundation
plan
was
most
popular
equalization
plans,
with
thirty-four
states
using
this
method
that
time.
Although
incorporated
vast
equalization
majority
formulas
states
into
had
respective
school
finance
systems
early
1970s
, the
degree
which
these
systems
were
truly
equalizing
was
questionable.
In 197
, the
President
s Commission
School
Finance
conducted
a nationwide
study
on the
*
i i l
Texas.
ratio
95th
percentile
to the
perc
entile
ranged
from
to 1.2
to 1
Maryland
to 5
to 1
Wyoming.
ratio
90th
percentile
10th
percentile
ranged
from
to 1
Georgia
and
West
Virginia
to 3
to 1
Montana
Clearly,
even
states
where
accomplished,
greatest
relatively
large
equalization
disparities
been
in per-pupil
financial
support
existed.
Similar
results
were
found
area
wealth
neutrality
among
states.
ratio
maximum
to the
minimum
to 1
property
North
Dakota
valuations
to 182
per-pupil
to 1
ranged
Kansas.
from
The
95th
North
to 5th
Dakota
percentile
to 9
ratios
to 1
ranged
New
from
Mexico.
to 1
90th
10th
percentile
Hampshire
ratios
North
ranged
Dakota
from
to 6
to 1
to 1
New
New
Mexico
is apparent
that
resource
accessibility
to fund
education
varied
widely
among
districts
states
(excluding
Hawaii,
which
included
no local
funding
schools
with
some
variations
being
extreme.
Because
continued
existence
these
inequalities
nation'
courts
became
a significant
- -- ^ -A -- 2 a --
SI I
_ _%- 1-,
-...-.--~-I
,~,,, L,~,
i L
s.
courts,
majority
from
early
1970s
through
present
These
challenges
to state
distributions
school
funds
will
be discussed
following
section.
School
Finance
Eauitv
Court
Cases
A plethora
challenges
to state
public
school
distribution
systems
have
been
decided
federal
state
court
systems.
Because
purpose
this
study
specifically
related
to distributional
equity
foundation
system
public
school
finance,
only
those
cases
which
have
involved
challenges
to foundation
systems
equity
grounds
will
discussed.
A small
number
of school
finance
equity
cases
have
been
decided
federal
court
system.
These
cases
involved
challenges
to funding
distribution
based
on the
constitutional
theory
equal
protection
clause
U.S.
Constitution.
claim
usually
made
was
that
system
funding
that
treated
students
distribution
in poorer
system
deprived
districts
unfairly,
students
poorer
districts,
as defined
per-pupil
property
wealth,
educational
opportunity.
These
cases
have
been
unsuccessful
in terms
reforming
state
funding
methodologies
to decrease
per-pupil
funding
disparities.
m 1 1. 1 -- r-
m b *
_ _%- "
r .
IIu
p
whether
Texas
system
financing
public
schools
was
violation
equal
protection
clause
fact
that
children
residing
school
districts
with
relatively
property
values
were
provided
an education
at a lower
level
funding
Such
than
disparities
children
funding
residing
level
in wealthier
allegedly
districts.
resulted
deprivation
educational
opportunities
these
children
. District
Court
Western
Texas
ruled
that
finance
system
indeed
violated
equal
protection
clause.
court
ruled
that
funding
disparities
created
suspect
classification
children
residing
poorer
districts,
that
these
children
were
denied
fundamental
right
of education
because
substandard
funding
court
applied
strict
scrutiny
test,
state
failed
to demonstrate
a compelling
interest
maintaining
such
a system
which
violated
this
fundamental
right.
. Supreme
Court
reversed
decision
on appeal.
Court
decision
declined
use
strict
scrutiny
standard
three
reasons.
First
, the
appellees
could
demonstrate
that
suspect
class
was
disadvantaged
system.
reason
existed
to believe
that
poor
people
state
resided
districts
with
lower
property
----1-~-~- An
J7
supplements)
children.
Therefore,
education
per
was
denied
child
state;
some
children
were
simply
others
Court,
provided
The
"does
Third,
fundamental
education
less
equal
funding
protection
require
Court
right.
was
extremely
absolute
ruled
Court
that
their
clause,
education
according
equality
education
declared
important
that
to society,
than
to the
advantages
was
although
was
province
court
to pick
choose
certain
substantive
rights
(such
guarantee
as education)
equal
protection.
to call
To be
fundamental
and
fundamental,
thus
such
a right
must
explicitly
or implicitly
mentioned
in the
Constitution.
Because
education
was
a fundamental
right
and
because
no suspect
class
was
involved,
according
to the
Court,
only
a rational
relationship
between
school
finance
stem
state
purpose
would
need
to be
demonstrated.
In the
Court
s view,
Texas
foundation
system
was
designed
to extend
education
to all
children,
to improve
quality
Legislature
had
chosen
facilitate
funding
schools
largely
through
local
sources
to promote
local
autonomy
control
education,
which
strongly
grounded
American
tradition.
Furthermore,
_
_ I 1
rational
relationship
test,
was
declared
Court
to be
in compliance
with
equal
protection
clause
Because
precedent
established
Rodriguez
case,
state
court
systems
became
primary
means
attacking
These
state
challenges
finance sy
typically
stems
on equity
involved
grounds.
allegations
violation
given
state
s constitutional
equal
protection
guarantee,
education
arti
constitution,
both.
overall
results
these
challenges,
terms
judicial
determination
distributional
equity
state
finance
systems
light
these
constitutional
provisions,
have
been
mixed.
The
landmark
case
challenges
to state
school
finance
distribution
methodologies
in state
court
systems
was
Serrano
Priest
allegation
was
that
disparities
in per-
pupil
funding
among
California
school
districts
(based
relative
equal
property
protection
values
clause
resulted
both
violation
California
of the
Constitution
Fourteenth
Amendment
to the
Constitution.
California
In its
Supreme
Court
decision,
eventually
court
decided
applied
case.
strict
scrutiny
test
this
to the
measure
state
school
because
finance
cation
system.
was
court
a fundamental
justified
right
SI e *
%I- ---_- --
- -~
i I
court
declared
"irrefutable"
fact
that
a suspect
class
consisting
discriminated
against
less
t due
wealthy
to the
individuals
nature
had
been
finance
system.
appellees
scrimination
individuals.
discrimination
against
court
affected
argued
school
that
districts
, however,
a class
ruled
people
system
, not
that
resulted
a class
this
residing
these
poor
districts.
court
also
ruled
that
education
was
a fundamental
right
which
clause
should
both
protected
constitutions.
equal
Education,
protection
according
to the
court
, was
significant
future
economic
social
success
students.
Education
was
also
declared
to be
necessary
an enlightened
citizenry
, capable
engaging
fruitful
civic
and
political
activities
Therefore,
finance
system
failed
strict
scrutiny
standard
because
state
could
demonstrate
no compelling
interest
in maintaining
year
following
Serrano,
a decision
New
Jersey
court
was
rendered
concerning
that
state
finance
distribution
system
issue
was
constitutionality
New
Jersey
foundation
system
funding
schools
Supreme
Court
New
Jersey
eventually
decided
case
, declaring
foundation
system
in violation
4
I
..
between
expenditures
overall
educational
quality.
Although
New
Jersey
time
case
ranked
third
nation
in terms
total
expenditure
per-pupil
education,
disparities
among
districts
were
nevertheless
large.
determine
The (
just
court
how
admitted
much
that
expenditure
although
per-pupil
was
was
difficult
enough,
clearly
some
districts
expenditure
was
totally
inadequate
(e.g.,
based
on such
factors
as conditions
facilities
academic
status
students).
The
court
believed
some
children
were
definitely
receiving
inadequate
education.
"thorough"
required
New
Jersey
Constitution
meant
thorough
something
beyond
education
minimum
therefore
was
according
being
to the
provided
court.
every
child,
constitutional
mandate
was
being
violated
Furthermore,
fostering
local
control
education
could
used
to justify
a system
with
huge
inequities
pupil
expenditures.
Real
control
was
illusory
poorest
local
districts
that
limited
resources
available
to them.
court
applied
strict
scrutiny
standard
to the
system
could
find
no compelling
state
interest
which
justified
school
finance
system.
court
expressed
_ -. -
L 1_
vl
I*
foundation
system
violation
. Constitution63
New
Jersey
Constitution.
Following
Serrano
Robinson,
state
foundation
distribution
formulas
many
states
were
challenged
respective
state
court
systems.
Michigan
s system
school
finance
was
challenged
that
state
s court
system,
claim
being
made
that
system
was
in violation
both
Michigan
. Constitutions.
U.S.
Constitutional
issue
was
disposed
court
citing
Rodriauez
as precedent
In deciding
state
constitutional
issue,
court
focused
on the
relationship
between
inputs
* .e.
available
monetary
resources)
and
educational
opportunities
court
stated
that
evidence
had
been
provided
that
students
in the
poorer
districts
were
significantly
more
deprived
educational
opportunity
than
students
wealthier
districts
The
court
further
stated
that
no proof
was
available
that
eliminating
per-pupil
funding
disparities
among
stricts
would
somehow
increase
opportunity
students
residing
in poor
districts.
state
s constitutional
obligation,
according
to the
court,
was
children
to provide
throughout
a basic
state.
system
The
schools
Michigan
Constitution
foundation
system
Michigan
was
upheld
as constitutionally
valid.
foundation
system
Idaho
was
challenged
violating
challenge
both
was
U.S.
based
on per-pupil
Idaho
Constitutions.
funding
The
disparities
resulting
from
a heavy
reliance
on local
valorem
taxation
to fund
education
Idaho.
Supreme
Court
Idaho
upheld
constitutionality
finance
system.
According
to the
court,
availability
funds
was
a very
important
factor
determining
educational
adequacy.
Yet,
Court
could
dare
that
smaller
expenditure
levels
resulted
declared
a denial
that
equal
Legislature
protection.
was
court
exercising
further
plenary
power
in developing
administering
a valid
system
financing
schools.
court
would
establish
itself
as a
"super
legislature"
interfere
with
this
authority.
court
unnecessary
found
in that
use
education
strict
was
scrutiny
a fundamental
test
right
state
as a rational
basis
developing
and
admini
control
steering
foundation
education.
program
Therefore,
fostering
foundation
local
plan
was
upheld
as constitutional.
constitutionality
Oregon
state
foundation
__
funding
schools
resulting
in alleged
deprivation
educational
opportunity
students
living
in poorer
areas
state.
Supreme
foundation
Court
Oregon
system.
upheld
court
constitutionality
not
answer
question
whether
education
was
a fundamental
right
therefore
subject
to equal
protection
guarantees
Nevertheless,
court
declared
that
no child
been
deprived
access
to a minimum
level
education
even
though
educational
program
offerings
available
to children
varied
widely.
court
system
was
agreed
to allow
that
local
the objective
control over e
education
finance
. While
admitting
that
lack
adequate
resources
diminished
local
control
poorer
district
, the
court
could
not
conclude
that
equal
protection
been
violated
because
such
diminution.
court
also
agreed
that
perhaps
other
systems
finance
could
developed
more
adequately
equalize
per-
pupil
expenditures
in education.
, the
court
saw
this
no reason
to strike
down
current
system
unconstitutional.
court
ruled
that
Oregon
Constitution
mandate
uniform
funding
per-pupil
across
_
_ *
A
I _
I
1
In West
Virginia,
school
finance
system
was
declared
unconstitutional
State
Supreme
Court
Appeals
based
on both
equity
adequacy
grounds.
court
ruled
that
mechanisms
thorough
free
financing
education
the
and
schools
equal
denied
protection,
children
both
violations
court
West
declared
Virginia
education
Constitution.
a fundamental
constitutionally
protected
right
West
Virginia
The
court
found
"broad
comprehensive
constitutional
inadequacies
structure
compos
ition"
entire
school
system,
including
method
finance
Some
districts
were
"woefully
inadequate,
" though
needed
some
degree
improvement.
finance
system
particular
was
declared
discriminatory
court.
Funding
should
have
been
emphasized
state
level
instead
local
to eliminate
funding
disparities
based
on local
wealth.
therefore
was
in violation
state
constitution
because
a thorough
effi
cient
system
schooling
was
being
provided.
Ohio
scrutiny
system.
Supreme
standard
Finding
Court
declined
examining
no fundamental
to apply
Ohio
interest
finance
strict
distribution
involved,
only
constitutionality
legislative
acts
should
assumed
unles
a clear
violation
were
evident.
The
purpose
state
promoting
, according
local
to the
control
court,
over
educati'
as a rational
on, a tradition
dating
back
to the
Northwest
Ordinance
1785.
Traditionally,
attempted
General
to ameliorate
Assembly
funding
through
disparities.
years
Although
per-pupil
funding
inequities
were
real,
system
was
irrational
Additionally,
wide
discretion
should
given
to the
General
Assembly,
court
should
exercise
great
circumspe
action
defer
legislative
insight
area
financial
provi
education.
Although
discretion
was
unlimited
General
Assembly
had
abused
to the
extent
that
finance
system
should
declared
unconstitutional
Therefore,
court
ruled
that
system
was
violation
Ohio
Constitution.
Georgia
Supreme
Court
ruled
that
state
school
financing
system,
despite
interdistrict
per-pupil
funding
inequities,
was
in violation
Georgia
Constitution.
state
financing
system,
according
court
, bore
a rational
relationship
to the
state
purpose
providing
a minimum
level
school
funding
to each
student.
court
admitted
that
finance
system
_
i
L_
--X
f
(wealthier
salaries,
districts
superior
could
curricula,
afford
higher
better
instructional
supplies
plant
facilities,
state
finance
scheme
constitutional
requirement
providing
basic
educational
opportunities
to all
children.
court
declared
that
although
state
should
beyond
educational
constitutional
opportunities,
requirement
providing
of providing
equal
basic
expenditures
child
was
reached
required
because
state
state.
Constitution
This
conclusion
provided
great
was
detail
about
institution
of education
mentioned
nothing
about
equalizing
expenditures
court
also
declared
that
although
education
was
vital
was
a fundamental
right
implicitly
or explicitly
guaranteed
ruling
Constitution.
non-fundamentality
U.S.
Rodriguez,
Supreme
Court
although
not
binding
with
regard
to state
constitutional
issues,
provided
worthy
guidance.
Therefore,
strict
scrutiny
model
was
used
Georgia
court.
The
court
decision
made
clear
that
Georgia
school
finance
system
was
a poor
one
in terms
equity,
and
urged
Legislature
to develop
a more
equitable
system
funding
schools.
Yet
court
refused
to rule
that
Al A%
--
to the
court,
term
"adequate"
was
specifically
defined
Constitution.
It would
have
been
difficult
determine
a judicially
manageable
standard
to determine
whether
pupils
are
rec
giving
an adequate
education,
court
declared,
it would
defer
to the
legis
lature
assess
adequacy
court
could
justify
declaring
state
school
financing
system
inadequate
because
per-pupil
funding
disparities
existed.
New
York
Court
Appeals
ruled
that
New
York
foundation
distribution
system
violate
either
New
York
Constitution
or the
equal
protection
clause
U.S.
Constitution.
court
in its
decision
declared
that
New
York
had
consistently
been
among
nation
leader
per-
pupil
school
funding.
Disparities
among
districts
did
exist,
metropolitan
areas
were
hardest
hit.
However
, no claim
had
been
made
that
district
provided
schooling
below
state
mandated
requirements;
only
disparities
were
question.
Because
complex
nature
funding
schools,
court
declared
that
was
best
left
to the
Legislature
staff
professionals
executive
branch.
Though
court
was
responsible
overseeing
compliance
with
constitutional
mandates
, no
violation
was
evidenced
in thi
case.
llr
1 _
education,
funding
disparitie
are
result
local
wealth
differences
legislative
actions
Therefore,
according
to the
court
, no violation
either
constitution
been
demonstrated.
Furthermore,
though
court
considered
education
important,
was
fundamental
right.
court
further
found
that
state
Constitution
required
only
that
a system
free
public
schooling
provided,
equitable
per-pupil
educational
funding.
state
had
complied
with
this
requirement
establishing
minimum
standards,
both
funding
other
educational
areas,
with
which
local
school
boards
must
comply.
Therefore,
school
finance
system
was
ruled
violative
of either
constitution.
Maryland
Supreme
Court
declared
that
state
s school
foundation
distribution
system
constitutionally
valid
light
. Constitution
, the
Maryland
Constitution,
Maryland
laration
Rights
With
regard
to the
state
was
constitutional
required
issue,
to provide
court
exact
ruled
funding
that
levels
state
pupil
event,
state
undertaken
through
years
provide
increased
equalization
expenditures
, and
current
formula
helped
ease
inequities.
"thorough
and
aC d1 *
K
I
education.
With
shared
responsibility
some
measure
funding
differentiation
should
expected.
Citing
Rodriauez112
dealing
with
U.S.
Constitutional
issue,
court
ruled
that
education
should
declared
a fundamental
right,
therefore
strict
scrutiny
should
applied
because
non-fundamentality
nonexistence
a suspect
class
based
on wealth
alone.
Furthermore
, no purposeful
discrimination
state
was
in evidence
Only
rational
basis
test
need
appli
state
had
a rational
basis
using
formula
state
foster
school
local
funding
control
formula
autonomy.
was
Therefore,
in violation
either
constitution
or the
Declaration
Rights.
The
Arkansas
Supreme
Court
declared
that
state
s school
finance
rational
system
unconstitutional
relationship
test
using
court
less
could
rigorous
find
rational
funding
relationship
among
between
districts
disparity
needs
per-pupil
individual
districts.
issue
in the
case
was
whether
financing
system
provided
state
foundation
plan
violated
Arkansas
Constitution.
court
use
strict
scrutiny
test
this
case,
therefore
avoided
question
whether
education
school
districts
rejected
claim
with
regard
that
to funding
purpose
court
foundation
plan
was
to promote
local
control
education,
declaring
that
provi
sion
more
equitable
funding
would
diminish
local
control.
Furthermore,
levels
-pupil
funding
deprived
poor
districts
effective
control
education.
In Oklahoma,
state
school
finance
system
was
charged
with
violating
equal
prote
action
clause
U.S.
Constitution
several
provi
sions
Oklahoma
Constitution.
rendered
a decision,
Oklahoma
declaring
Supreme
Court
system
eventually
constitutionally
valid.
challenge
to the
system
was
that
inequitable
per-pupil
foundation
funding
plan d
levels
eprived
which re
children
suited
from
distri
state
with
lower
property
violation
declared
values
opportunity
equal
that,
under
protection
equal
a good
clause
protection
education,
court
legislative
analysis,
acts
such
as the
foundation
plan
should
considered
valid
courts
unless
a suspect
class
been
deprived
rights
fundamental
right
been
violated.
Citing
Rodriauez
court
found
that
neither
these
conditions
existed.
Furthermore,
allegation
was
III 1
control
relationship
education
D existed
autonomy,
between
therefore
system
a rational
a legitimate
state
purpose.
plaintiffs
decision
argued
Rodri.uez126
that
need
U.S.
apply,
Supreme
that
Court
different
circumstances
existed
Oklahoma
than
Texas.
Court
claimed
that
state
school
systems,
including
funding
plans,
were
dissimilar.
Oklahoma
court
had
no reason
The
to rule d
plaintiffs
differently
charged t
than
hat
state
. Supreme
school f
Court
financing
system
was
in violation
several
provisions
state
constitution.
First,
because
education
is specifically
mentioned
Oklahoma
Constitution),
should
Constitution
qualify
unlike
as a fundamental
U.S.
right
court,
however,
ruled
that
mere
mention
education,
other
establish
phenomenon,
state
as a fundamental
constitution
right.
Furthermore,
providing
equitable
funding
per-pupil
was
mentioned
Oklahoma
Constitution.
Second,
plaintiff
argued
that
funding
inequities
resulted
a violation
constitutional
requirement
uniformity
application
laws
throughout
state.
The
court
countered
that
Legislature
established
plaintiffs
challenged
use
valorem
taxation
foundation
plan,
claiming
that
resultant
funding
disparities
violated
equal
protection
clause
Oklahoma
Constitution.
court
rejected
this
argument,
saying
that
foundation
plan
been
established
minimize
differences
caused
varying
levels
district
wealth
court
further
held
that
was
obligated
uphold
constitutionality
a given
Legislature
Legislature
unless
acted
could
arbitrarily
demonstrated
that
or capriciously.
Court
could
find
no such
violation
with
regard
to the
school
finance
legislation.
Thus,
finance
system
was
upheld
constitutional.
In South
Carolina,
foundation
distribution
system
was
upheld
State
Supreme
Court
valid
light
South
Carolina
Constitution.
According
to the
court,
Legislature
was
constitutionally
mandated
to provide
system
schooling,
Legislature
discretion
how
to fund
system.
Legislative
actions
such
those
relating
to funding
schools
should
normally
considered
valid
courts.
plaintiffs
also
charged
that
students
residing
poor
districts
were
denied
equal
educational
opportunity
state
money
poor
districts.
Therefore
system
was
rational
means
equalizing
educational
opportunity
Montana
foundation
distribution
system
was
charged
with
violating
Montana
Constitution.
plaintiffs
charged
that
although
state
finance
system
included
interdistrict
equali
zing
provi
sions,
per-pupil
funding
differences
among
school
districts
were
as high
as eight
one,
thus
equal
opportunity
was
being
denied.
The
defendants
argued
that
state
foundation
plan
had
been
established
to foster
equal
opportunity,
and
therefore
constitution
was
violated.
Additionally,
according
to the
defendants,
outputs
(i.e.,
assessments
based
factors
such
as standardized
test
scores
dropout
rates
should
have
been
used
measure
equal
opportunity
instead
inputs
* e.,
funding
defendants
further
argued
that
although
equal ed
control
Constitution
ucational
school
established
opportunity,
ng as a state
as a goal
document
goal.
With
state
declared
local
local
control
naturally
disparate
-pupil
spending
levels
occurred.
Montana
Supreme
Court
ruled
that
system
was
violation
constitution.
court
declared
that
state
failed
to present
convincing
evidence
that
outputs
rather
than
inputs
signified
equal
educational
opportunity
goal
a constitutional
state
to equalize
guarantee.
educational
Because
expenditures
failure
(due
part
to the
state
inadequate
failed
funding
to provide
foundation
equal
educational
program)
opportunity
children.
Texas
foundation
distribution
was
charged
with
violating
differences
Texas
in the
property
Constitution
wealth
based
school
on huge
districts
Because
percent
school
funding
statewide
was
derived
from
local
sources
because
localities
relied
heavily
volarem
taxation,
wide
school
funding
disparities
resulted.
A 700
to 1
ratio
in property
value
existed
between
wealthiest
poor
school
stricts,
while
per-
pupil
spending
was
to $2
Supreme
Court
Texas
declared
school
finance
system
unconstitutional.
court
stated
that
amount
money
spent
on pupils
a significant
impact
on educational
opportunity.
Pupils
residing
in poor
districts
were
cycle
poverty
which
deprived
them
educational
opportunity.
These
poor
districts,
despite
normally
taxing
at a higher
rate,
still
raised
less
revenue
than
wealthy
districts,
thus
giving
their
schools
a reputation
inadequacy.
Industry,
a key
increasing
local
wealth,
was
court
through
funding
admitted
years
disparities
that
attempted
through
Texas
to lessen
Foundation
Legislature
interdi
School
had
strict
Program
(FSP).
Although
was
designed
to provide
more
state
money
provided
poorer
district
to guarantee
enough
minimum
funding.
moneys
The
had
court
been
declared
that
constitutional
mandate
state
had
been
FSP.
Much
concept
court
efficiency
s discussion
as found
revolved
state
around
constitution.
court
necessarily
therefore o
declared
exc
outside
that
lusive
judi
cial
determination
realm
efficiency
political
control.
was
system
constitution
give
exclu
sive
discretion
legislature
determining
what
efficient.
Although
"effi
cient"
was
spec
ifically
defined
constitution,
a standard
was
provided
courts
use
to determine
whether
constitution
had
been
violated.
court
cons
titutional
duty
to determine
whether
legi
slature
was
fulfilling
constitutional
duty
state
argued
that
"efficient"
meant
simple
and
inexpensive.
According
The
to the
court
found
court,
no evidence
school
this
system
to be
claim.
efficient
This
was
case,
therefore
school
system
was
financially
efficient.
In Kentucky
school
finance
system,
which
included
foundation
as well
as a guaranteed
yield
component,
was
challenged,
charge
being
that
large
school
funding
disparities
among
Kentucky
districts
violated
both
U.S.
Kentucky
Constitutions
Kentucky
Supreme
Court
declared
finance
program,
as well
entire
state
public
school
system
, in violation
Kentucky
Constitution.
high
court
in its
deci
sion
condemn
system
in light
U.S.
Constitution,
declaring
that
because
educational
system
been
ruled
violation
Kentucky
Constitution
an analysis
Constitutional
issues
was
necessary.
litigation
revolved
largely
around
concept
efficiency.
representatives
state
argued
that
because
Kentucky
Constitution
required
Legislature
provide
an efficient
system
schools,
General
Assembly,
courts,
was
organization
responsible
determining
whether
system
was
indeed
effi
cient.
court,
however,
ruled
that
constitutional
authority
review
legislation
which
established
school
finance
system
to determine
constitutionality.
I
supporting
because
efficiency
was
required
state
Constitution.
high
court
agreed
that
efficiency,
to a large
degree,
referred
to substantial
uniformity
resources
being
applied
throughout
school
system,
resulting
substantial
equal
opportunity
a good
education.
The
court
relied
on the
testimony
experts
who
claimed
that
significant
expenditure
positive
overall
correlation
quality
existed
between
of education,
and
level
that
students
who
were
provided
lower
levels
funding
were
prone
to receiving
a lower
quality
education.
These
experts
presented
data
showing
that
districts
with
per-pupil
expenditures
more
restricted
curricula
lower
overall
achievement
test
scores.
Therefore
, the
court
ruled
that
an efficient
system
common
schools
had
been
provided
because
substantially
different
levels
school
funding
among
districts
throughout
state.
Because
heavy
reliance
on local
resources
fund
public
schools
resultant
per-pupil
expenditure
differences
based
on relative
local
property
values,
General
Assembly
created
an inefficient
educational
system.
Supreme
Court
agreed
that
although
General
Assembly
had
recent
years
passed
legi
slation
summary,
challenges
to school
foundation
distribution
methodologies
in state
courts
have
with
mixed
success.
specifically
with
1 of
the
the c
equity
ases
discussed
effects
dealt
state
foundation
formulas
distributing
school
funds.
next
section
includes
a discussion
theoretical
framework
well
foundation
as examples
state
system
foundation
school
systems
finance
which
provide
a funding
component
equalizing
local
discretionary
revenues.
Foundation
Method
Financing
Schools
A foundation
program
financing
education
one
which
state
local
districts
contribute
jointly
to the
financing
education
such
a way
that
each
child
provided
a minimum
educational
program.
In order
accomplish
this
each
student,
foundation
program
based
on the
ability
districts
this
minimum
educational
program.
In other
words,
level
state
support
varies
inversely
with
local
wealth,
thereby
providing
each
district
a foundation
fiscal
support
educational
programs.
Under
a foundation
system,
theoretically,
poorest
taxing
equity
effort.
are
Thus,
recognized
both
with
per-pupil
this
as well
distribution
taxpayer
tem.
state
under
a foundation
system
generally
establishes
minimum
local
property
rate
which
districts
must
pass
order
base
receive
expenditure
state
each
funding
district
Additionally,
obtained
a minimum
to state
support.
Theoretically,
beyond
foundation
level
local
districts
are
able
to provide
funding
finance
additional
programs
or services
above
and
beyond
foundation
level
within
parameters
established
state
constitution
statutes.
Such
additional
funding
cause
disequalizing
effects
system
overall.
foundation
plan
includes
a legislatively
determined
minimum
program
from
which
a local
share
, based
legislatively
determined
rate
subtracted.
remainder
amount
support
from
state
necessary
to finance
such
a program.
Operationally,
amount
state
determined
follows
x State)
- (Vali
x state
where
state
to the
district,
- I. *
I
* *a
1 1
I
district,
state
rate
local
district
The
foundation
amount
established
state
multiplied
number
pupils
to produce
total
foundation
funding
that
district.
From
this
product
subtracted
amount
district
is required
contribute,
assessed
total
based
on the
valuation
foundation
local
that
funding
rate
district.
level
total
difference
amount
between
contributed
district
amount
state
to that
district
Currently
thirty-eight
states
use
some
modification
foundation
program
to support
public
education.
Such
funding
program
as a rationale
provision
each
child
child
state
resides
a foundational
a relatively
level
wealthy
education
local
whether
school
district
states
or a poorer
to take
one
an active
Yet,
funding
despite
role
this
order
recognition
to equalize
a minimally
acceptable
level
children,
nearly
every
one
these
states
allows
local
districts
to apply
locally
determined
millage
rates
in order
levy
funds
above
foundation
level
guaranteed
state.
Although
states
impose
certain
limitations
restrictions
on the
amount
use
these
additional
funds,
effects
may
nonetheless
disequalizing.
additional
separately
equalized
discretionary
equalized
through
funds
state.
a resource
levied
The
accessibility
districts
second
are
level
program,
either
guaranteed
base
(GTB)
or guaranteed
yield
(GTY).
A brief
discussion
operationalization
typical
GTB
and
GTY
programs
is provided
followed
a discussion
distribution
systems
states
that
at the
time
this
writing
use
or have
recently
used
a GTB
or GTY
to augment
foundation
formula.
and
GTY
systems
are
similar
to the
foundation
plan
through
that
state
include
support
equalizing
in inverse
educational
proportion
opportunity
to districts'
ability
pay.
Unlike
a foundation
state,
a state
using
or GTY
system
does
establish
a minimum
foundational
level
levied
educational
districts.
support
Rather,
a minimum
levels
rate
support
to be
are
locally
equal
determined.
access
Thus,
resources,
and
rather
than
GTY
formulas
minimum
include
funding
level
included
foundation
program.
GTB
plan
operates
on the
assumption
that
districts
should
have
access
to the
same
base
wealth
per-
pupil.
state
establishes
a guaranteed
base,
and
state
simply
provides
each
district
sufficient
funding t
hat,
expenditures
as well
as the
local
rate.
The
GTY
similar
to the
GTB
except
that
state
sets
a tax
yield
level
property
in the
state
rather
than
a tax
base
GTB
have
identi
formulas
formulas
are
mathematically
expressed
follows
Expi
x Adj
.Val
where
state
to distri
number
students
dollar
as calculated
per-pupil
state
expenditure
strict
set
Expi
district
state
share
percentage
factor
, and
.Val
is the
ratio
asses
valuation
per-pupil
district
i compared
to that
average
assessed
valuation
districts
This
method
is equitable
in terms
both
-pupil
funding
and
taxpayer
effort
Every
child
is guarantee
certain
level
funding
commensurate
with
or her
educational
local
nee
school
same
given
strict
levy
pupil
level
Each
, thus
tax
mill
effort
effort
promoting
equity
exerted
results
among
taxpayers.
Several
states
currently
use
or have
recently
used
funding
scheme
which
involves
a foundation
component
*1 S S -
1_1
I 1
to a district
is a product
weighted
pupil
count
times
guaranteed
financial
support
base
minus
local
fair
share,
which
participation
contribution
applied
local
the
based
to assessed
contribution
foundation
on a state
property
required
program.
mandated
equalized
millage
at 40
local
e rate
percent
market
value,
or a rate
which
would
generate
percent
district
s foundation
amount,
whichever
smaller.
GTB
component
is available
only
to districts
below
90th
percentile
in terms
property
wealth
per-pupil
that
levy
taxes
above
state
mandated
millage
rate.
additional
mills
above
state
mandated
level,
state
pays
difference
between
amount
actually
generated
and
amount
that
would
be generated
applying
village
rate
to the
assessed
value
property
in a district
at the
90th
percentile
In Montana,
a foundation
program
is supplemented
component.
foundation
level
support
is variable
according
to categories
based
on average
number
belonging
(ANB),
which
represents
enrollment.
foundation
level
thus
increases
with
ANB.
state
provides
funding
this
foundational
level
category
after
subtracting
portion
which
raised
county
level.
No equalization
r .-
* .
I ~ 1
I
* *
which
are
classified
isolated.
These
districts
must
raise
percent
foundation
amount.
Under
component
districts
levy
additional
mills
general
fund
counties
teacher
retirement
average
fund.
mill
state
yield
guarant
each
ees
these
a yield
equivalent
permissive
mills
Oklahoma
public
schools
are
financed
a foundation
program
supplemented
Salary
Incentive
Aid,
which
comparable
district
to a GTY
determined
supplement.
Foundation
multiplying
a legi
each
slatively
established
Base
Foundation
Support
Level
weighted
Average
Daily
Membership
(ADM).
State
foundation
determined
taking
assessed
this
product
valuation
subtracting
district
mills
from
times
previous
year
plus
mill
county
levy
other
minor
adjustments
Distri
further
apply
millage
rates
above
fifteen
mill
foundation
portion
Salary
Incentive
Aid
portion
assure
component,
a guaranteed
in which
yield.
the
Stat
state
provides
Salary
funds
Incentive
Aid
determined
multiplying
an incentive
guarantee
district
s ADM
then
subtracting
number
additional
mills
times
assessed
valuation
district
In Kentucky
state
provides
funding
to augment
district
difference
between
what
was
raised
through
application
a state
mandated
village
rate
on assessed
valuation
local
property
what
was
required
to meet
aggregate
foundation
per-pupil
funding
level
Districts
are
permitted
to exceed
this
minimum
foundational
level
, and
those
that
chose
to do
so are
provided
matching
funds
from
state
to exceed
percent
their
entitlement
ensure
a minimum
yield.
revenue
obtained
through
this
additional
statewide
levy
per-pupil
equalized
property
at 150
percent
assessment
average
Districts
are
permitted
increase
financing
an additional
percent
without
a matching
grant
from
state
A three-tiered
finance
system
used
Texas
was
recently
invalidated
Texas
Supreme
Court
However
, a brief
discussion
of the
system
existed
prior
invalidation
court
will
provided
to exemplify
operationalization
foundation
distribution
systems
augmented
or GTY
components.
Texas
system
included
a foundation,
a GTY
and
unequalized
component.
With
Tier
, the
foundational
component,
state
granted
a district
difference
between
at a certain
amount
required
foundation
to fund
level
each
what
student
was
actually
s education
levied
above
foundation
millage
rate
a certain
dollar
level
per-
pupil
each
additional
cent
rate,
a maximum
rate
taxation.
Under
Tier
additional
millage
rates
above
guaranteed
yield
band
were
permitted
matched
state
funds
present
study
included
data
from
foundation
distribution
system
state
Florida
fiscal
year
-93.
Florida
schools
were
funded
through
foundation
system,
although
state
equalize
dollars
raised
through
application
discretionary
or capital
outlay
maintenance
caused
millage
revenues
rates
raised
The
through
degree
h the
disequalization
application
these
millage
rates
was
focus
present
study.
following
studies
section
Florida
includes
s public
a review
education
previous
funding s
equity
system.
Previous
Florida
School
Finance
Eauitv
Studies
This
method
study
public
focused on
education
equity
finance
aspects
. The
foundation
foundation
plan
state
Florida,
Florida
Education
Finance
Program
(FEFP),
was
chosen
study.
following
discussion
includes
a summary
previous
equity
studies
related
to the
FEFP.
II
* 1
I
I
research
questions
which
are
specifically
relevant
to the
present
study.
first
included
extent
to which
inequalities
distribution
educational
revenues
existed
prior
to and
after
implementation
FEFP.
second
available
included
education
extent
were
to which
related
level
to district
revenues
wealth
before
and
after
implementation
FEFP.
Vaughan
examined
fiscal
data
1972-73
school
year
, prior
implementation
FEFP,
1973
, 1974
, and
1975-76
school
years,
after
FEFP
implementation
Vaughan
s conclusion
with
regard
to distribution
per-
pupil
revenues
was
that
FEFP
was
relatively
equitable.
vast
majority
Florida
s public
school
pupils
fell
between
tenth
ninetieth
percentile
district
mean
state
local
revenue
pupil.
range,
restricted
range,
federal
range
ratios
state
and
local
per-pupil
revenue
among
districts
were
relatively
after
FEFP
implementation.
Although
coefficients
variation
local
revenue
-pupil
were
relatively
high,
they
were
lower
after
FEFP
implementation
than
before
In the
area
fiscal
neutrality
, Vaughan
found
a strong
relationship
revenue,
between
with
local
effect
wealth
increasing
local
per-pupil
in strength
across
r
1
I
implementation
FEFP,
was
nevertheless
significant.
Vaughan
concluded
that
FEFP
was
very
wealth
neutral,
although
greater
wealth
neutrality
was
evident
Florida
after
implementation
FEFP.
Carroll
states,
including
portion
Park
conducted
Florida.
tudy,
which
equity
The
was
analyses
intent
a follow-up
five
Florida
to a similar
study
conducted
equity
Florida
Carroll
state
1979
was
distribution
compare
system
before
current
finance
formula
(FEFP)
with
tribution
which
existed
prior
implementation.
Includ
ed in
study
were
fiscal
comparisons
made
school
year
(before
FEFP)
against
1975-76
school
year
(after
FEFP
implementation).
These
comparisons
were
made
in terms
instructional
expenditu
res
as well
as revenues
six
levels
aggregation
These
included
general
revenues
including
Racing Co
Racing
mission
Commission
funds,
funds,
general
general
revenue
revenues
including
PL 874
revenues,
local
plus
state
revenues
, local
plus
state
plus
revenues
, and
total
revenues.
Carroll
Park
found,
through
a series
regression
equations,
significant
relation
hips
between
wealth,
based
assessed
valuation,
per-pupil
revenues
at all
levels
between
instructional
expenditures
wealth
both
before
and
after
implementation.
Carroll
and
Park
found
no significant
relationship
between
household
income
revenues
instructional
expenditures
per-pupil
before
FEFP,
yet
a significant
relationship
FEFP
community
after
resulted
s tax
implementation.
in a weakened
effort
The
relationship
availability
implementation
between
school
revenues
as well
as instructional
expenditures
Carroll
Park
concluded
that
in terms
both
per-
pupil
widene
revenue
availability
disparities
resulted
instructional
after
expenditures,
implementation
FEFP.
new
program
became
less
fiscally
neutral,
decline being
included in t
attributed
cost
formula.
adjustment
overall
factor
conclusion
reached
Carroll
Park
was
that
reform
benefitted
larger
more
urban
districts
more
readily
than
slightly
smaller
less
urban
ones.
greatest
benefit
reached
poverty
prone
school
districts
Alexander
Shiver
studied
equity
distribution
school
funds
Florida,
comparing
equity
that
existed
before
FEFP
implementation
to equity
after
implementation.
Data
from
1970
1971-72
school
A a S a
r
amA~l M A m
_I_
Alexander
Shiver
studied
levels
aggregation.
first
included
total
state
local
per-pupil
revenues
second
foundation
funds
per-pupil.
Each
level
revenue
was
studied
light
several
equity
related
statistics.
In the
both
area
range
total
and
-pupil
restricted
revenue,
range
an increase
distribution
was
evident.
standard
deviation
distribution
doubled
during
variation
foundation
years
remained
funds
study,
virtually
pupil,
while
same.
distribution
coefficient
In the
range
area
quadrupled
from
1970-71 to
1980-
while
restricted
range
nearly
quadrupled.
variation
Both
standard
increased
between
deviation
1970-71
coefficient
1980-81
area
foundation
funds
pupil
Gini
coefficients
increased
overall
after
implementation
FEFP
, both
in terms
total
state
and
local
revenue
per
pupil
foundation
fund
per
pupil.
These
coefficients
demonstrated
a decreased
level
equity
1980-81.
Alexander
Shiver
conducted
correlational
analyses
between
variables
two
which
levels
were
revenue
claimed
seven
to provide
independent
indication
between
assessed
value
per-pupil
foundation
funds
per-
pupil
as well
as personal
income
per-pupil
and
foundation
fund
per-pupil
implied
that
equalization
establi
shed
prior
to the
FEFP
been
maintained
FEFP.
overall
conclusion
Alexander
Shiver
based
on the
analysis
these
data
was
that
greater
equity
had
not
been
achieved
with
implementation
FEFP.
Stark,
FEFP
Florida
Honeyman,
in a study
Lottery
Wood
specifically
on public
examined
related
school
equity
to the
financing
aspects
effects
state.
study
included
basic
analy
ses.
first
was
degree
to which
lottery
funds
distributed
through
FEFP
(approximately
provided
to public
substitute
percent
school
existing
sources
total
state)
school
lottery
were
funds
used
funding
during
1989
school
year.
second
analysis
, the
one
relevant
to the
present
study
, included
an examination
remaining
lottery
fund
those
distributed
through
special
allocations
rather
than
FEFP
itself.
Specifically,
this
second
analysis
dealt
with
whether
these
lottery
funds
distributed
through
FEFP
had
effect
on the
equity
distribution
public
education
funds
s- i-- -
state.
a^-,
Three
I- -
levels
1 -I
aggregation
were
used
- I S -
1
'm
special
allocations
from
state's
general
revenue
fund
included
allocation
the
funds
FEFP.
, and
Third,
lottery
the FEFP
funds not
funds,
special
distributed
through
FEFP.
boxplots
showed
similarity
variation
distributions
first
levels
aggregation,
with
increased
variation
with
introdu
tion
lottery
proceeds.
Both
range
restricted
range
demonstrated
decreased
level
equity
when
moving
across
levels
increased
aggregation.
across
federal
levels
range
aggregation,
ratio,
though
demonstrated
that
Florida
system
was
equitable.
variance,
standard
deviation,
coefficient
variation
across
demonstrated
levels
cumulatively
aggregation.
disequalizing
relative
effects
mean
deviation,
on the
other
hand,
indicated
cumulatively
increased
equity
effects.
Gini
coefficient
FEFP
alone,
aggregation
level
pertinent
to the
present
study,
was
calculated
.00916
system.
reduced
, demonstrating
a great
Interestingly
.00261
, the
.00380
deal
Gini
horizontal
coefficients
, respectively,
across
equity
were
other
levels
aggregation.
Indexes
were
slightly
smaller,
.97185
.97283
, for
other
levels
aggregation.
result
Gini
Coeffi
cient
McLoone
Index
computations
demonstrated
that
least
1989
school
year,
FEFP
provided
an equitable
system
distributing
school
funds.
study
, however
addr
ess
equity
effects
scretionary
capital
outlay
maintenance
millage
levi
es.
These
effects
, for
1992
school
year
, were
addressed
present
study
O'Loughlin,
Wood
, and
Honeyman
examined
equity
distribution
FEFP
dollars
most
specifically
looking
at the
effects
revenues
provided
sparsity
supplement
formula
on per
-pupil
equity.
The
data
were
on the
1990
FEFP
calculation
including
federal
distributions
or capital
outlay
or debt
service
funding
In the
O'Loughlin
, Wood
, and
Honeyman
study
, four
elements
each
were
element
studied
being
with
examined.
cumulative
These
equity
included
effects
foundation
program,
program
supplements
, the
discretionary
local
levy
categorical
special
allocations
Within
each
element
additional
revenues
res
ulting
from
sparsity
supplement
were
examined
to determine
equity
effects
standard
deviation,
coefficient
variation,
McLoone
index,
Gini
coefficient
demonstrated
a cumulatively
sequali
zing
effect
FEFP
across
four
elements
without
sparsity
supplement,
an increased
disequalizing
effect
across
four
elements
in all
measures
except
revenues
McLoone
provided
index
sparsity
Gini
coefficient
supplement
were
when
included.
disequali
school
zing
trend
stricts
occurred
below
across
median
four
when
sparsity
element
supplements
were
included.
Gini
Coefficient
demonstrated
equalizing
trend
across
four
elements
when
sparsity
revenues
were
included.
With
regard
(correlation
coeffi
to the
cient,
wealth
coeffi
neutrality
cient
measures
determination,
slope
regression)
, a cumulatively
increase
association
pupil r
account
revenues
the sp
between
wealth
resulted
arsity
per-pupil
formula
. With
supplement
district
without
taking
per-
into
inclusion
sparsity
supplement
revenues
, a cumulative
decrease
in the
strength
association
variables
occurred.
The
overall
conclusion
was
that
basic
part
FEFP
was
relatively
equitable
, but
addition
supplements,
cretionary
dollar
categorical
dollars
bore
a strong
inverse
relationship
to the
relative
property
wealth
district.
The
sparsity
supplement
effect
reducing
this
relationship.
O'Loughlin,
Wood,
Honeyman
demonstrated
through
this
study
that
FEFP
distributed
school
funds
in an equitable
fashion
1990
school
year,
with
levies
generated
from
application
discretionary
millage
rates
having
slightly
tem.
disequalizing
study
FEFP
cifically
effects
light
examine
related
effects
capital
overall
equity
outlay
maintenance
village,
which
coupled
with
discretionary
levy
was
focus
present
study.
Currie
examined
equity
resources
capital
outlay
FEFP
Florida,
and
part
revenues
which
derived
included
from
assessments
capital
both
outlay
maintenance
village
rate.
Using
1988-89
data,
Currie
examined
four
levels
funding.
first
included
FEFP
operating
expenditures
, which
consisted
FEFP
allocation,
seventh
period
allocation,
prior
year
adjustments,
required
local
effort.
The
second
third
capital
levels
outlay
consisted
total
funding
total
dollar
dollar
value
value
state
local
capital
outlay
funding
, respectively
fourth
final
The
results
examination
at the
first
level,
FEFP,
third
level,
local
capital
outlay
funding
, were
interest
in the
context
present
study.
Results
examination
equity
FEFP
element
provided
evidence
of the
relative
equity
foundation
system
existed
during
that
fiscal
year.
third
level
included
an equity
assessment
revenues
generated
through
application
local
capital
outlay
and
maintenance
millage
rates.
Although
this
level
was
more
broadly
defined
to include
other
local
sources
capital
outlay
financing,
confounding
capital
outlay
maintenance
levies
with
other
local
sources,
examination
results
provided
insight
present
study.
levies
generated
through
application
discretionary
millage
rates
were
examined
Currie
study.
The
FEFP
level
funding
demonstrated
greatest
degree
equity
among
four
levels
studied
in terms
horizontal
equity
measures.
per-pupil
range,
restricted
range,
interquartile
range
, and
federal
range
ratio
were
calculated
.65,
$305
.15, $
.03,
.13,
respectively.
standard
deviation,
coeffi
cient
variation
, and
relative
mean
deviation
per-pupil
were
.04,
, respectively.
McLoone
Index
was
In the
area
wealth
neutrality,
Gini
Coefficient
FEFP
equity
level
correlation
was
an indication
coefficient
between
nearly
local
perfect
assess
valuation
local
property
expenditures
per-pupil
was
entire
distribution
distribution
within
a 95
percent
confidence
interval
around
mean
value.
resultant
coefficients
determination
were
.24,
respectively.
author
suggested
that
a strong
relationship
between
wealth
FEFP
exist
results
horizontal
equity
measurements
local
capital
outlay
funding
level
indicated
less
equitable
distribution
than
FEFP.
per-pupil
range,
restricted
range,
federal
range
ratio
, and
interquartile
range
were
calculated
at $
.59,
$731
.11,
and
.32,
respectively.
standard
deviation,
coeffi
cient
variation,
relative
mean
deviation
were
calculated
$217
.49,
.85,
, respectively.
McLoone
Index
was
calculated
distribution
below
median.
results
from
wealth
neutrality
measures
demonstrated
a less
equitable
distribution
from
local
capital
outlay
sources
than
from
FEFP.
Gini
Coeffi
cient
was
calculated
correlation
coefficient
between
local
assessed
valuation
per-pupil
and
coefficients
determination
were
.63,
respectively.231 The
of wealth neutrality
author
this
suggested
area
that
existed.
major
violations
Again,
revenues
resulting
maintenance
from
millage
the a
rates
application
were
capital
confounded
with
outlay
revenues
from
other
local
sources
capital
outlay
financing.
Nonetheless
, the
capital
outlay
maintenance
levies
contributed
to the
relatively
inequitable
distribution
determined
Currie
study.
summary
, though
various
elements
equity
distribution
aspects
FEFP
have
been
studied,
a need
existed
examine
equity
effects
distributions
resulting
from
discretionary
capital
outlay
and
maintenance
exhaustive
levi
present
analysis
this
study
research
represents
question.
Conclusion
This
chapter
began
with
a discussion
historical
process
which
state
governments
assumed
more
active
roles
providing
financial
support
to school
districts
recognition
need
to provide
less
wealthy
localities
larger
ideal
state
state
grants
support
to make
was
smaller
developed
bases.
early
This
scholarly
_
half
twentieth
century,
state
distribution
methodologies
judicial
were
stems
providing
level
tested
to determine
students
education.
in the
American
state
state
results
federal
governments
an equivalently
these
cases
state
were
adequate
in terms
school
finance
equity
reform
were
mixed.
Following
was
discussion
foundation
system
funding
school
most
common
previous
distribution
research
studies
system
currently
concerning
equity'
in use.
y effects
Finally,
this
Florida
funding
system
were
discussed.
purpose
discretionary
foundation
system.
this
millage
The n
study
was
levies
ext
to analyze
on the
chapter
fiscal
includes
effects
equity
a presentation
specific
methodology
which
these
effects
were
examined.
Notes
1Ellwood
Cubberley,
School
Funds
Their
Anportionment
(New
York:
Columbia
University,
1906).
4Ibid.,
3Ibid.,
4Ibid.
5George
Education in
Macmillan, 1
Strayer
State <
.9
Robert
New
York,
Haig,
vol.
(New
Financina
York:
23).
9Ibid.,
176.
10Harlan
: Financial
State
Rural
Schools
Updegraff
SuDDoort
Rural School Surv~v Vnrlr
U *-
(Ithaca
, NY: The
, 1922)
Joint
Committee
11Ibid.,
12Ibid.,
136.
110-115.
13Henry
University o
:. Mori
Chicago
son,
Press
School
, 1930
Revenue
(Chicago,
14Ibid.,
15Ibid.,
16Ibid.,
195.
208-214.
200.
17Paul
York:
Teachers
Mort,
College,
-- -
Columbia
University,
(New
1924
18Ibid.,
19Ibid.,
20Ibid.,
8-11.
e.g.,
Schools
State
(New
Suonort
American
Reusser
Company,
John W.
York
for
fnr
council o
, Public
Inc.,
Polley
Paul
: Teachers
Public Ed
2ulcEua o
Mort,
State
College,
n Education,
School Fina
1941);
, Publi
Publi~~.. ScolPanns rnrun ir
Paul
1933
nc e
Mort,
SuoDort
1926
Public
; Paul 1
(Washington,
; Paul
(New
York:
Walter
McGraw-Hi
. Reusser,
ca r olry/\ d r
Mort,
* .
and
The
Walter
11 Book
Structure.
ODeration
(New
, 1960).
York:
McGraw
-Hill
Book
Company,
Edgar
Programs,
Finanrs (
" in
' ]PIW
Morphet,
R.L.
Vn lr
"Characteristics
John
(ed.
Mzt- 4 nr 1
State
P~r~obl ems rhn
r. y ,-, n a n a
Support
a
- 2a
School
School
rce
Issues
I
, Rural
W
SuIrvpv
YVrL
NTew
Measurement
Educational
Need
ucation
Mort
I
, Problems
i
Srhrorl
r
Educational
Finance
Programs
(Gainesville
, FL: National
Education
Finance
Project,
1971)
4Ibid.
5President
Existinga
State
C ommi
School
ssion
Finance
on School
Programs
Finance
Review
(Washington,
United
States
Government
Printing
Office,
1972
26Ibid.,
27Ibid.,
. Const.
amend.
XIV
29Julie
Underwood
Deborah
Verstegen,
"School
Finance Ch
Protection
Verstegen
on Public
allenges
Analy
(eds.),
School
S1S
in Federal
," in Julie
he Imoacts
Finance
(New
Cour
K.
of L
York:
ts: Changing
Underwood an
itication an
Harper
Equal
Deborah A.
Legislation
& Row,
1990)
Antonio
Independent
School
District
SRodriguez,
(1973)
31Id.
at 17.
San
Antonio
Independent
School
District
Rodriauez,
F.Supp
33Id.
280.
at 282.
34San
Antonio,
. at
17-23.
35Id.,
36id.
37id.
38Id.,
23-24.
at 24.
at 33.
33-34.
- Ar
42Id. ,
43Id.
53-54.
at 55.
44William E.
State Courts,
Sparkman,
" in Julie K.
"School Finance Challenges in
Underwood and Deborah A. Verstegen
(eds.)
, The Impacts of Litigation and Leaislation on Public
School Finance
(New York:
Harper
& Row,
1990),
193.
45487
P.2d 1241
(1971
46Id.
47Id.
at 1244.
1250.
48The case was decided prior to the precedent
established by
Rodriauez
of using the rational
relationship
standard in light
Amendment
equal
of alleged violation of
the Fourteenth
protection clause.
49Serrano,
P.2d
at 1250.
50Id.,
51Id.0
1250
1252
-125
-125
52Id.,
53Id.,
54Id.,
1255-1256.
1256-1259.
1259-126
55Robinson v
SCahill,
A.2d 187
(1972).
56Id.,
57Id.,
58Id.,
59Id.
-190.
199-200.
at 205.
63The case was decided prior to
the precedent
established by
Rodriauez
of using
the rational relationship
standard in light of alleged violation of
Amendment
equal
the Fourteenth
protection clause.
64Robinson,
A.2d at
217.
65Milliken v.
Green,
212 N.W.2d 711
1973).
66Id.
67Id.
68Id.,
69Id.
70id.
at 714.
716.
716-718.
at 719.
at 720.
71Thomoson v.
Enkelkina,
P.2d
(1975)
638-640.
641-642.
72Id.,
73Id.
74Id.
75Id.,
76Id.,
642.
642-645.
646-653.
7701sen v
State,
P.2d 239
(1976).
78Id.,
79Id.,
80Id.,
81id.
140-142.
144-145.
145-146.
147.
84Id. at 878.
85id.
86id.
878-883.
88Board of Education of City School District.
etc.
Walter,
390 N.E.2d 813
(1980)
89Id. at 819.
90id.
91Id. at 820.
92Id. at 821.
823-826.
94Id. at 822.
95McDaniel v.
Thomas,
285 S.E.2d 156
(1981).
96Id. at 159.
160-161.
164-165.
99San Antonio,
411 U.S. 1
(1973).
100McDaniel, 285 S.E.2d at 167.
101Id. at 168.
165-166.
103 Board of Education. Levittown.
etc. v. Nvouist, N.Y.,
AqQ 1T F 2c1
(f1 QR2)
97Id.,
98Id.,
87Id.,
93Id.,.
102Id.,
106San Antonio, 41]
107Levittown, N.Y.,
U.S.
(1973).
439 N.E.2d at
364-365.
at 368-369.
109Hornbeck v.
Somerset County Board of Education,
A.2d
(M.D.
1983
1101d.
lllld.,
at 776.
776-780.
112San Antonio,
U.S.
(1973).
113Hornbeck,
458 A.2d at
787-788.
114Id.,
115Id.,
116Id.,
782-783.
786-787.
788-790.
117Duoree v
Alma School District no.
S.W.2d 90
(1983).
118Id.,
119Id.
92-93.
at 93.
120Eair...School_inanctCouncil
Oklahoma,
P.2d 1135
_~o Oklahoma. mc>... v
-
(1987
121Id.
122Id.
1138.
1144.
123San Antonio,
U.S.
(1973).
124Fair School Finance
P.2d at
1144-1146.
Incr.
108Id.
of0klahoma
1148.
128id.
129id.,
130id.,
131Id.
132id.,
133Id.,
134id.
1148-1149.
1149-1150.
1150.
1141-1142.
1142-1143.
1150.
135Richland County v.
Camobell,
1988)
364 S.E.2d
(S.C.
136Id.,
471-472.
137Helena Elementary School District No.
Montana,
P.2d 584
1 v. State of
(1989)
686.
689.
690.
138Id.
139Id.
140Id.
141Id.
142Id.
at 690.
691.
143Edaewood Indecendent School District
V Kirby.
S.W.2d 391 4
144Id.
145id.
1 AK--,
(1989
at 392.
at 393.
1 v. State of
v
Kirbyv.
,
149Rose
Council
Better
Education.
S.W.2d 186
(1989
. at
151Id.
152Id., 2
153Id. at
-209
-213
213.
. Craig
Wood
David
Thompson,
Education
Finance
Analvsi
Law
: Cons
titutional
of Strategies
Challenges.
(Topeka,
to State
KS: National
Aid
Organi
Plans
zation
: An
Legal
Problems
in Education,
1993),
155David
Honeyman,
Practices
Thompson
Fiscal
(White
Leader
Plains
. Craig
shin
Wood
Schools
, NY: Longman
, and
David
: Concerts
Publishing
and
Group,
1994
220.
156Ibid.
, 221.
157Wood
and
Thompson
158Thompson,
Wood
, and
Honeyman
159Ibid.
160Ibid.
161Stephen
Andrea
United
. Gold
Hyary
States
, David M
Public
Canada.
1990
. Smith
School
-91,
, Stephen
Finance
B Lawton,
Programs
Albany
, NY
Center
Study
States
, 199
'bzIbid.
163Ibid.
164Deborah
. Verstegen,
r~mmn oo
School
Finance
IP~ fiirnr h r-ta
at a Glance
loon\
Inc .,
, 26
, 18
ha la- t
150Id
154R
iInamroT"
I
I I I w
167Ibid.,
168Ibid.,
169Ibid.,
226.
228.
229
-230
171Ga.
172Ga.
173Ga.
Code
Code
Code
20-2-165(b)
20-2-164.
20-2-166.
174Mont
. Code
20
-301
to 20
-368
175Mont
. Code
Ann
. 20-0-301
to 20-9
176Mont
. Code
Ann
-367
to 2
-9-368.
. Code
-109
Sch.
Code
-109
(B) (3
179Ky
180Ky
181Ky
. Rev
. Rev
. Rev
. Stat
. Stat
. Stat
. Ann.
. Ann.
. Ann.
.470
.440
.440(2
Carrollton-Farmers
Branch
IndePendent
School
Dist.
Texas
S.W.2d
(1992)
183Tex
184Tex
185Tex
. Educ
. Educ
. Educ
. Code
. Code
. Code
Ann
Ann.
Ann
. 16
. 16
.252
.302
.303.
186David
Finance
Reform
Vaughan,
on Poor
"The
Impact
Minority
>f Florida
Children,
s 1973
" in
School
Robert
nI nA n fl
r.-
170Ibid.
177Ok.
1780Ok.
f ^ %y ^jn
rr rrk AC )" A
e t1 h
nhhr
189Ibid.,
25-37.
190Stephen
Eauitv
Press,
School
Carroll
Finance
Rolla
(Cambridge,
Park,
MA.: The
1983).
Search
Ballinger
191Stephen
Finance
: Results
Corporation,
. Carroll
frn
Search
(Santa
Eauitv
School
Monica,
Rand
1979).
192Carroll
193Ibid,
194Ibid,
195Ibid,
196Ibid.
197Ibid,
Park,
84-85.
85.
87.
199Kern
Florida
(Summer
School
, 1983)
Alexander
Districts,
d Lee Shiver,
" Journal of
"Equalization
Education
Among
Finance
, 55-62
200ibid.,
201ibid.,
202ibid.,
203ibid.,
204ibid.,
205ibid.,
-Inc
55-56.
56-57.
57-59.
59.
59-61.
62.
-In .
from
Pi \r/
StCatesQ
198Ibid,
I
of
199
School
3), 23
Funding,
1-242.
" Journal
Education
Finance
(Winter,
207Stark,
Florida
Honeyman,
Wood,
Lottery,
208Stark,
Florida
Honeyman,
Wood,
Lottery,
209Stark,
Florida
Honeyman,
Wood,
Lottery.-
210Stark,
Florida Lottery
211Stark,
Florida Lottery
212Stark,
,
Honeyman,
, 15-16.
Honeyman,
and
Honeyman,
Wood,
Wood,
Wood,
An Examination of the
An Examination of the
An Examination of the
An Examination of the
An Examination of the
An Examination of the
Florida
Lottery,
213j.
Honeyman,
Michael
A Studvy
O'Loughlin, R
f the Effects
. Craig
Wood, an
Sna-rsit t-
n tt Cn.an
David
on the
Ecuitv
(Gainesville,
of the
FL: UCEA
Florida
cation
Center
Finance
Education
Program
Finance,
1992).
14Ibid.,
215Ibid.,
216Ibid.,
217Ibid.,
218Ibid.,
13-14.
12.
14-24.
19-24.
24.
219Gaylon
Capital
Outlav
Currie,
Fund incr
An Examination
nf Publi
Education
-- -: --p--'a'a'.'-t ~ .~ S ~.J ar*A J s o.1.
litv
Eauitv
of the
Current
Methhnd
fl tr bt c Thd-n
Outlay
Fundinca
General
in the
itures
State
ir Education
PFl nr ral
(Doctoral
Eauitv
Dissertation,
- -- -
ExDend
Suoolement
A Comr a !i/"
DistributinG
Capital
222ibid.,
223ibid,
224ibid,
225ibid.
226ibid,
227ibid.,
228ibid.,
229Ibid.,
230ibid.,
231ibid.,
232ibid.,
120-126.
127-128.
128-129.
145-146.
132.
115-120.
120-126.
127-128.
128-129.
145-147.
153.
CHAPTER
METHOD
present
raised
through
study
local
focused
on the
discretionary
effects
millage
rates
revenues
on the
fiscal
equity
a foundation
school
distribution
system.
previous
chapter
relevant
literature
was
reviewed
chapter
includes
a discussion
method
which
these
equity
effects
were
examined.
chapter
begins
with
a discus
population
from
which
data
were
derived.
Following
a description
education
funding
system
Florida,
state
chosen
study
the design
discussion
next
data.
method
section
provides
chapter
through
a description
concludes
which
with
disequalizing
ects
local
levies
were
assessed.
Population
foundation
distribution
system
state
Florida
was
chosen
this
study
Several
reasons
were
involved
selection
Florida
as the
target
state.
First,
Florida
education
funding
system
was
well
suited
w
Additionally,
local
districts
authority
to rai
scretionary
levi
, and
revenues
generated
these
levies
were
equali
zed by
state.
Thus,
intuitively
possibility
disequalizing
exists
effects
that
when
these
added
levi
introduced
revenues
generated
through
was
foundation
to determine
program.
magnitude
purpose
these
study
disequalizing
effects
they
indeed
existed.
ond
, although
at the
time
of thi
writing
current
foundation
system
Florida
avoided
a major
equity
court
deci
sion
foundation
program
state
is susceptible
an equity
lawsuit.
Thus,
equity
effects
such
as those
examined
in the
present
study
might
relevant
in the
context
future
equity
court
decisions
Third
, the
people
Florida
are
guarant
a fi
scally
equitable
system
financing
public
schools
Funds
school
to be
stributed
such
a manner
as to
. guarantee
to each
student
Florida
public
and
which
any
school
services
0: ^ ^0
are
similar
differences
system the
appropriate
substantially
student
availability
to his
equal t
notwiths
varying
loca
programs
educational
o those
standing ge
1 economic
nee
available
graphic
factors.2
& a
m
I a
Fourth,
results
from
recent
studies
have
indicated
that
foundation
portion
Florida
s funding
system
relatively
equitable.
Therefore,
a good
baseline
existed
from
which
this
study
operated.
present
study
included
an assessment
discretionary
degree
levies
disequalization
on a relatively
equitable
introduced
foundational
system.
Fifth
states
Florida
one
one
nation
nation'
largest
most
public
populous
school
enrollments.
Additionally,
both
population
in general
and
school
enrollment
in particular
have
been
growing
rapidly
relative
to the
significant
from
nation
as a whole.
a national
Therefore
perspective
Florida
Following
is a more
detailed
cuss ion
population
present
study.
public
school
system
Florida
divided
into
sixty-seven
local
distri
, each
countywide.
In 1990-91,
state
served
an unweighted
full-time
membership
enrollment
district
with
largest
was
Dade
at 356
smallest
was
Glades
with
.46.
enrollment
Florida
s public
schools
seen
pattern
overall
growth
since
1970s
, while
nationally
school
enrollments
have
declined
slightly
during
that
time.
1989
enrollment
Florida
s public
schools,
however,
Florida
grew
public
steadily
school
during
this
enrollment
period.
was
In 1969
1,312
, the
Enrollment
had
grown
to 1
1979
,646
,583
1989
Total
expenditures
Florida
public
school
increased
rather
dramatically
during
this
same
time
period
In 1969
, total
expenditure
were
$961
273,000
In 1979
, expenditures
grown
to $2
,531,000
1989
-pupil
expenditures
likewise
have
undergone
a sharp
increase.
-pupil
expenditures
Florida
public
schools
were
,461,
3,198
, and
4,497
1969
, 1979
, and
1989
, respectively
The
average
statewide
per-pupil
expenditure
was
1990
per-pupil
expenditure
among
districts
ranged
from a
$3,836
high
Clay
County
Hamilton
following
County tc
a section
Sa low
provides
description
how
funds
are
distributed
to Florida
school
districts
FEFP
Florida
s public
schools
are
funded
primarily
through
Florida
school
funding
Education
mechanism
Finance
since
Program
1973
(FEFP),
basi
state
component
finance
more
specific
educational
needs
various
local
school
districts
Following
a brief
introductory
overview
calculation
FEFP
formula
1992-93,
after
which
a more
detailed
discussion
system
provided.
The
funds
distributed
to each
local
school
district
through
equivalent
FEFP
(FTE)
were
calculated
enrollment
each
multiplying
specific
full-time
program
education
program
cost
factor
assigned
Legi
the
slature.
base
student
resultant
allocation.
weight
This
FTEs
product
were
was
multiplied
multiplied
district
cost
differential,
which
accounted
disparate
costs
living
communities
served
various
districts.
To this
new
product
supplemental
allocations
were
added,
depending
declining
on district
enrollment
eligibility.
supplement, s
These
sparsity
included
supplement,
funding
adjustment.
When
eligible
supplements
had
been
added,
result
was
total
state
local
dollars
which
district
was
entitled.
required
local
effort,
amount
district
was
required
to contribute
order
to participate
FEFP,
was
subtracted,
resulting
State
FEFP
contribution
to that
school
district.
this
aggregate
amount
moneys
to be
distributed
to the
local
school
districts
from
state
annually
determined
through
legi
slative
appropriation
1992-93
a total
was
appropriated
from
state
treasury
to be
distributed
to the
local
stricts
through
FEFP.
this
, $40
,500,00
was
appropriated
from
State
School
Trust
Fund
remainder
from
General
Revenue
Fund.
formula
was
enrollment
driven,
therefore
each
district
funding
was
based
on weighted
FTE.
Each
district
s weighted
was
calculated
through
surveys
taken
throughout
year
student
membership
various
programs.
each
program
area
was
weighted
according
to cost
factors
ass
signed
to the
individual
program
areas.
The
weighted
district
was
product
each
program
area
program
area
s cost
factor.
In utilizing
these
program
cost
factors,
differences
educational
costs
based
on grade
level
differences
and
differences
based
on program
instruction
were
recognized.
Grade
level
programmatic
cost
factors
were
incorporated
into
FEFP
which
were
designed
to base
financial
support
on these
system
differences
of unequal
use
treatment
cost
of unequals
factors
, which
resulted
addressed
weighted
base
FTEs
student
as determined
allocation
herein
were
(BSA)
multiplied
was
set
at $2
Florida
Legi
slature
1992
school
year
Three
adjustments
were
made
to thi
amount
in recognition
varying
fiscal
conditions
faced
local
cost
stricts
differential,
These
declining
included
enrollment
district
supplement
and
sparsity
supplement.
district
cost
differential
was
intended
equalize
distributions
to districts
on the
relative
costs
living
associated
with
community
they
based
serve
on the
cost
Florida
factors
Price
used
Level
formula
Index
were
as determined
Office
Governor
Specifically
, the
sum
last
three
year
indexes
were
divided
three
multiplied
.008
added
to 0.200
In the
1992
Appropriations
, these
differential
were
indexed
such
a way
that
lowest
value
was
1.000
Additionally
, the
stricts
were
placed
in regions
corresponding
districts
state
in a given
region
s judi
were
cial
given
circuits
and
highest
all
value
calculated
district
region.
declining
enrollment
supplement
was
intended
allocation.
these
eligible
districts,
percent
decline
was
multiplied
prior
year
FEFP
unweighted
FTE
added
to the
current
year
allocation
sparsity
supplement
was
intended
ass
rural
stricts
that
faced
additional
cost
burdens
assoc
iated
with
population
sparsity
, higher
per
pupil
transportation
costs
An allocation
was
provided
to districts
with
an unweighted
ess
A total
,000
,000
was
distribute
ed through
sparsity
supplement
1992
school
year
result
addition
eligible
supplements
product
weighted
BSA
was
total
gross
state
local
FEFP
dollars
available
to the
distri
A funding
adjustment
was
applied
ensure
that
distri
received
same
percentage
change
in funding
as occurred
1991
From
this
result
aggregate
required
local
effort
RLE)
was
subtracted.
district
S RLE
was
based
product
valuation
millage
property
rate
Following
local
a di
assessed
scussion
method
ch the
millage
rates
districts
were
determined.
aggregate
required
local
revenue
used
general
or 1
local
amount
was
at $3,034
Using
rolls
provided
Department
Revenue,
commissioner
education
computed
millage
rate
which
when
applied
to 95
percent
total
nonexempt
property
in the
state
would
generate
proscribed
aggregate
required
local
effort
result
was
basic
millage
rate
districts.
Equalization
factors
were
then
used
to determine
specific
millage
rates
individual
districts.
factor
a given
district
was
equal
to the
quotient
prior
year
year
s state
aggregate
s assessment
assessment
that
district
level
divided
, subtracted
prior
from
one.
resultant
equalization
factor
was
then
multiplied
basic
millage
rate
to determine
RLE
millage
rate
district
School
board
approval
RLE
millage
rate
was
required
order
a given
district
receive
FEFP
funds
from
state.
subtraction
required
local
effort
from
gross
state
local
FEFP
dollars
resulted
state
FEFP
dollars.
To this
amount
funding
adjustments
were
made,
which
accounted
arithmetical
errors,
roll
changes,
errors
or other
allocation
errors.
result
these
adjustments
was
net
state
FEFP
dollars
combination
state
FEFP
funds
required
local
effort
Because
these
categorical
programs
special
allocations
were
special
without
included
Community
part
funding
being
analysis
programs
discussed
Comprehensive
Schools
detail
School
35 School
present
are
study,
listed
Categorical
Construction
Lunch,
these
briefly
programs
Debt
36 Instructional
Service,
Materials
Student
Transportation.
Special
Allocations
were
Blue
Print
Schools,
Career
Summer
Preparation,
Inservice
Pre-School
Institutes,
Projects,
Programs
Safe
Emphasis,
Full
Service
School
s/Interagency
Cooperation,
and
Education
Business
Cooperative.
local
Florida
revenue
given
used
year
to support
derived
public
from
schools
property
taxation.
Local
school
districts
are
authorized
to tax
property
support
education
Florida
Constitution.
support
effort
public
school
Five
categories
schools.
operating
millage,
millages
first
are
used
required
as established
local
FEFP
The
second
scretionary
village,
determined
each
local
school
board
(within
statutory
limitations)
without
a vote
electorate.
third
capital
outlay
maintenance
millage,
determined
each
school
board
Without
a vote
electorate.
remaining
millage
districts
exceeding
effort,
are
prohibited
10 mills
from
discretionary,
Florida
Constitution
combination
capital
outlay
from
required
and
local
maintenance
rates
a given
year
present
study
nonvoted
focused
millage
on the
rates
disequalizing
, discretionary
effects
millage
and
school
capital
improvement
village,
when
combined
with
revenues
obtained
through
equalized
foundation
portion
FEFP.
Thus,
focus
was
on the
disequali
zing
effects
rates
which
each
were
applied
at local
board
discretion.
discretionary
village
rate,
levie
from
which
were
equalized
state,
was
determined
each
individual
school
board
without
a vote
local
electorate.
Districts
were
permitted
use
revenues
obtained
from
application
discretionary
millage
rate
to support
current
operations.
Legislature
annually
prescribes
maximum
discretionary
millage
rate
that
districts
choo
never
to exceed
mills
The
1992-
maximum
discretionary
millage
rate
was
set
at 0
.510
mills
Florida
Legislature.
capital
outlay
maintenance
millage
rate
given d
districtt
was
determined
local
school
board
rates.
These
revenues
could
used
district
new
construction
modeling
projects,
sites
site
improvement
or expansion
new
sites
, existing
auxiliary
facilities
or ancillary
iliti
or to fund
maintenance,
renovation,
repair
existing
school
plants
These
revenues
could
furthermore
used
to support
pupil
transportation
their
use
in purcha
sing
school
buse
driver
vehicle
education
, security
vehi
vehi
, plaint
maintenance
or vehicle
related
related
to storing
or distributing
material
equipment
New
or replacement
equipment
could
also
purchased
using
these
funds.
stricts
through
were
capital
permitted
outlay
use
maintenance
revenues
rate
obtained
payments
educational
facilities
sites
under
a lease-
purchase
agreement
, as
long
as these
funds
exceed
one-
half
total
levy
from
village
rate
The
revenues
could
used
payment
certain
loans
used
finance
school
facilities
These
loans
were
restricted
term
one
year
or 1
ess
, unl
ess
otherwi
extended
lender
never
exc
four
years
Additionally
, the
amount
loan
could
exceed
one-
fourth
total
volarem
revenue
from
preceding
fiscal
year
Districts
could
also
use
these
revenues
pay
costs
Finally
, these
revenues
could
used
to support
payment
costs
leasing
relocatable
educational
facility
three
nonvoted,
locally
derived
millage
rates
used
support
school
, only
required
local
effort
portion was
equalize the
levies
supplemented
stribution
levies
matching
among
resulting
state
districts.
from
fund
The
capital
in order
discretionary
improvement
millages
were
equalized
on a statewide
basi
disequalizing
foundation
effect
program
these
revenues
levie
is the
when
focus
combined
this
with
study
following
section
includes
a discussion
spec
ific
method
which
these
equity
effects
were
examined
Desian
study
addr
ess
question
what
extent
did
local
discretionary
levies
introduce
sequalizing
effects
into
an equalized
foundation
program
previous
section
included
a summary
FEFP
as it operated
1992-93
scal
year
current
section
includes
a discussion
design
study.
scal
equity
realm
education
finance
refers
to fairness
in the
distribution
fiscal
resources.
examination
fiscal
equity
a distribution
stem
revenues
are
used
to represent
resource
availability
equity
studio
In the
current
study
, per-pupil
revenues
were
chosen
choosing
per
as the
-pupil
measurement
revenues
object
as opposed
rationale
to per-pupil
expenditures
was
fact
that
revenues
could
matched
with
their
millage
rate
source
, whereas
expenditures
were
identified
such
a source.
Thus
, in the
present
study
per-
pupil
revenues
was
representative
resources
used
support
education.
To determine
degree
disequity
caused
introduction
scretionary
millages
revenues
millages
, per-pupil
revenue
raised
capital
s were
through
outlay
examined
application
maintenance
across
seven
levels
aggregation.
first
level
included
per-
pupil
the F
revenues
EFP
stributed
An examination
through
this
foundation
aggregate
level
portion
provided
seline
from
which
degree
disequali
zation
caused
local
second
discretionary
third
levi
was
level
assess
aggregation
included
stribution
among
local
distri
-pupil
revenues
raised
through
application
discretionary
capital
outlay
maintenance
millage
rates
, respectively
An analyst
-pupil
revenues
stribution
these
included
combination
discretionary
and
capital
outlay
level
maintenance
indicated
levies,
total
results
degree
from
disequalization
this
resulting
from
levies.
fifth,
sixth,
seventh
levels
aggregation
included
combinations
first
through
fourth.
The
fifth
aggregation
through
level
included
foundation
per-pupil
portion
FEFP
revenues
combined
distributed
with
per-pupil
revenues
raised
through
application
discretionary
millage
rate.
sixth
level
aggregation
included
a combination
per-pupil
revenues
distributed
through
foundation
portion
FEFP
combined
with
per-pupil
revenues
raised
through
application
capital
outlay
maintenance
millage
rate.
results
from
these
levels
, when
compared
to the
results
from
aggregate
level
one,
indicated
through
application
magnitude
inequity
of each
introduced
unequalized
millage
rates,
respectively.
seventh
combination of the
foundation program,
final
per-pupil
the per-
level
aggregation
revenues
pupil
distributed
revenues
included
through
through
generated
application
discretionary
millage
rate,
per-
pupil
revenues
generated
through
application
capital
only
demonstrated
revenues
generated
total
through
disequalizing
millage
effects
rates
Per-pupil
revenues
across
these
seven
level
aggregation
were
examined
light
three
standards
fiscal
equity
These
included
resource
access
sibility
, wealth
neutrality
these
techniques
, and
concepts,
through
yield.
coupled
which
Following
with
they
a discussion
specific
were
each
quantitative
assessed.
Measurement
previous
design
section
data
included
study
a de
cription
In this
section
method
which
fiscal
equity
was
measured
presented
most
equity
studi
resource
accessibility
, wealth
neutrality
, and
yield
have
been
means
assess
relative
equity
a distribution
In the
present
study
measures
related
to all
three
these
equity
constructs
were
used
assess
degree
disequali
zation
introduced
millage
rates.
In the
present
study
, the
revenues
generated
through
application
discretionary
capital
outlay
and
maintenance
village
rates
were
examined
to determine
effects
on student
resource
accessibility
Resource
*
_
ii ii
m R
I
I_
|
|
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PAGE 1
AN EXAMINATION OF THE EFFECTS OF LOCAL SCHOOL DISTRICT DISCRETIONARY LEVIES ON THE FISCAL EQUITY OF A STATE FOUNDATION DISTRIBUTION SYSTEM BY JEFFREY A. MAIDEN A DISSERTATION PRESENTED TO THE GRADUATE SCHOOL OF THE UNIVERSITY OF FLORIDA IN PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF DOCTOR OF PHILOSOPHY UNIVERSITY OF FLORIDA 1994
PAGE 2
Dedicated to the memory of my stepfather, Dr. John Robert Snyder.
PAGE 3
ACKNOWLEDGEMENTS I express my deep appreciation to my Lord and Savior, Jesus Christ. I thank Hirn for His unlimited, matchless grace, for providing eternal salvation to the human race, and for making this dissertation possible. The support and guidance of my committee chair, Dr. R. Craig Wood, has been invaluable He has been my mentor and teacher over the last four years, and I could never express my true appreciation for what he has done. Thanks also go to my committee cochair, Dr. Davids. Honeyman. Through Dr. Honeyman I have acquired an appreciation of school finance data analysis as well as the proper perspective of never taking "stuff" too seriously Acknowledgement goes to Dr. M. David Miller, from whom I have developed an appreciation, respect, and fascination of research data analysis and educational measurement. Further acknowledgement goes to Dr. Linda S. Crocker for providing the opportunity to acquire college teaching experience. Thanks go to Dr. James Hensel for always being available for support and direction in the dissertation writing process. lll
PAGE 4
Last but not least I would like to express my deep appreciation to both parents and stepparents. Their support and encouragement during this entire process has been crucial. iv
PAGE 5
TABLE OF CONTENTS ACKNOWLEDGEMENTS .......................................... iii ABSTRACT . . . . . . . . . . . . . . . . . . ............. vii CHAPTER 1 INTRODUCTION ...................................... 1 Purpose of the Study ...................................... 3 Research Question ....................... ........ .......... 5 Significance of the Study ................................. 5 Limitations ............................................... 6 Delimitations ............................................. 6 Overview of the Methodology ............................... 7 Design of the Study ....................................... 8 Notes ..................................................... 8 CHAPTER 2 REVIEW OF THE LITERATURE ......................... 11 The Theory of Per-pupil Funding Equity ............ .... ... 12 School Finance Equity Court Cases ........................ 20 Foundation Method of Financing Schools ................... 43 Previous Florida School Finance Equity Studies ... ....... 51 Conclusion ............................................... 63 Notes .................................................... 64 CHAPTER 3 METHOD ........................................... 7 7 Population ............................................... 77 FEFP ..................................................... 80 Design ................................................... 89 Measurement .............................................. 92 Conclusion .............................................. 110 Notes .......... ............ ...... ... ... ...... ... ........ 111 CHAPTER 4 RESULTS ....... .......... .. ....... ........ ....... 117 Resource Accessibility .................................. 118 wealth Neutrality ....................................... 124 Tax Yield ............................................... 13 0 Conclusion .............................................. 132 Notes ................................................... 134 V
PAGE 6
CHAPTER 5 DISCUSSION ............. ... .............. .... .... 135 Summary .. ... .......... .. .............. .... .. .......... 13 5 Observations .... .... ..... .............. . ..... ... .. ..... 137 Conclusions ............................................. 141 Implications ................... . ..... ... .... .. ..... 143 Notes ................................................... 146 APPENDIX A APPENDIX B FEFP COST FACTORS ....... .... .. ... ... .. ..... 147 RAW DATA ....... .... ......... .... .. .. ... .... 148 LIST OF REFERENCES .. ...... ...... . .... .. ... .... .. ...... 151 BIOGRAPHICAL SKETCH ... ............... .. ........ .. ........ 15 7 vi
PAGE 7
Abstract of Dissertation Presented to the Graduate School of the University of Florida in Partial Fulfillment of the Requirements for the Degree of Doctor of Philosophy AN EXAMINATION OF THE EFFECTS OF LOCAL SCHOOL DISTRICT DISCRETIONARY LEVIES ON THE FISCAL EQUITY OF A STATE FOUNDATION DISTRIBUTION SYSTEM By Jeffrey A. Maiden August, 1994 Chairman: R. Craig Wood Cochair: David S. Honeyman Major Department: Educational Leadership This quantitative study was designed to examine the disequalizing effects of local school district discretionary levies when applied to a foundation system of education finance. The data used in the study were obtained from the 1992-93 Florida Education Finance Program, which included an equalized foundation component and two separate discretionary revenue sources. These discretionary sources, the current operation discretionary levies and the capital outlay and maintenance levies, were based entirely on property taxation and were not equalized by the state. The system was examined in light of fiscal equity concepts of resource accessibility, wealth neutrality, and vii
PAGE 8
tax yield. Resource accessibility measures indicated increasing variability in distribution of resources as discretionary revenues from either of the two sources were added to foundation revenues. The capital outlay and maintenance levies contributed more to the resource accessibility variation than the current operation discretionary levies. The addition of discretionary revenues from each source demonstrated noteworthy disequalizing effects on the wealth neutrality of the distribution system. The effects of the capital outlay and maintenance revenues were more acute than the effects of the current operation discretionary revenues. Both discretionary revenue sources decreased the level of equivalence of tax yield when combined with the foundation revenue source. The capital outlay and maintenance source had far more disequalizing effects in the realm of taxpayer equity than the current operation discretionary source. Replications of the current study in states with similar systems of education finance are warranted. Additionally, studies into the fiscal equity effects as well as the costs of incorporating statewide equalization programs for the discretionary levies are recommended. viii
PAGE 9
CHAPTER 1 INTRODUCTION Fiscal equity as it relates to financing schools has a rich tradition in the education finance literature. 1 Broadly defined, fiscal equity in school finance refers to a condition of fair treatment of all students, that students in a given state should be provided equivalent support for education given their varying educational needs. 2 Because of the broad nature of the theory of fiscal equity, Jt is best understood if divided and defined by various components. The following section includes a short description of the theory of fiscal equity through analysis of its components. Chapter 2 of this study provides a more complete discussion of the development of the theory of equity in the realm of financing education. Fiscal equity is most commonly discussed in terms of the degree of equity among two groups, students and taxpayers. Equity among students is a reference to the basic fairness of distribution of educational resources among all students. Most per-pupil equity studies include examination of equity in light of three categories, specifically horizontal ~quity, vertical equity, and wealth neutrality. 1
PAGE 10
Horizontal equity refers to an equal treatment of equals. A horizontally equitable condition is one in which equal resources are available to pupils with equal needs. 3 Vertical equity, conversely, refers to unequal treatment of unequals. Because students have varying educational needs, varying levels of resources per-pupil are necessary to meet these needs. Under the concept of vertical equity such differences are taken into account. 4 2 Wealth neutrality, alternatively known as fiscal neutrality or equality of opportunity, is the degree to which the support for the education of students is related to the wealth of the state, but not the local community in which they are educated. A wealth neutral condition is one in which the fiscal support for students is not related to the fiscal conditions of local school districts. 5 Taxpayer equity refers to the basic fairness among the taxpayers of a state in terms of their support for education. Taxpayer equity exists to the extent that equal tax effort in support of education results in equal resources per-pupil. 6 Education finance researchers have also been interested in other theoretical considerations of school funding systems. Most common are adequacy, efficiency, and excellence 7 Adequacy is a reference to whether all students have an acceptable level of funding to support their education. 8 Thus, whereas equity stresses distributional
PAGE 11
3 fairness adequacy stresses the acceptability of the level of support throughout the distribution. Excellence refers to the concept of attainment of a high degree of educational quality. In the school finance context, excellence implies fiscal support sufficient to fund such quality. 9 Efficiency, on the other hand, as a finance construct implies maximizing educational output given minimum resources. 10 Though adequacy, excellence, and efficiency are significant constructs worthy of further research, equity has a longer history as a school finance theory and has generated a tremendous number of individual studies. 11 Purpose of the study A foundation system of school funding is pertinent in the context of fiscal equity in that the system theoretically provides funding to guarantee each and every child in the state a minimally acceptable level of education. Because each child is guaranteed this foundational level of funding, in theory equality of educational opportunity is provided through the distribution system. Yet, despite this recognition by states to take an active funding role in order to equalize to a minimally acceptable level for all children, foundation systems typically include allowing local districts to levy additional local taxes, given certain restrictions and limitations, which may not be equalized by the state. 12 In other words, a state using a foundation formula provides
PAGE 12
funding to assure each child a minimally acceptable level of education, represented by the foundation funding level, but allows districts the discretion to raise funds beyond this minimum. 4 Because a foundation funding plan is designed to promote equity, tension results when unequalized discretionary levies are permitted. Thus, discretionary millage rates and the resultant levies are problematic in the sense of equity. According to Wood and Thompson, The problem is perplexing. If the state equalized local leeway, the scheme would no longer be a minimum foundation. If the state fails to equalize discretionary millage, it restores the inequality it first sought to eliminate. Further, if the state did not to permit discretionary millage, the minimum concept is once again thwarted. The basic fact is that any unaided discretionary millage counters equalization, while denying local leeway violates minimum intent. The only other option is to limit the amount of discretionary millage, but it is clear that this solution is only a compromise. 13 According to Thompson, Wood, and Honeyman, three problems related to equity emerge if districts are permitted / to levy discretionary dollars to supplement a minimum foundation program. First, the basic foundation program does not include provisions for equalization of funds derived from millage rates above the minimum foundation level. Second, districts must spend less if the discretionary millage is not applied. Third, in poor districts spending resulting from discretionary levies is less because these levies are not equalized 14 The present study was designed to address the
PAGE 13
5 problem related to the inclusion of discretionary levies in a minimum foundation program Research Question The research question addressed in this study was, "In a state with a foundation program for support of schools including one or more discretionary millage rates, to what extent do the levies resulting from the application of the discretionary millage rates introduce inequities into the system for distributing education funding?" Significance of the study The study was intended to make a contribution to the theory of per-pupil fiscal equity, which is rich in the school finance literature and is the focus of a great deal of research activity among school finance scholars. The study was intended to provide insight to the problem of allowing local school districts to strive for providing the best possible education for children within the parameters of the distribution formula while maintaining fiscal fairness throughout a state. The foundation program is by far the most popular method of financing public education. Currently, thirty-eight states use a foundation program to distribute dollars for education. 15 Because of this popularity the funding methodology was considered worthy of further research.
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6 The foundation system of the state of Florida was chosen for this study. Florida is one of the most populous states in the nation and serves one of the largest public school enrollments. This study was intended to provide an examination of the public school system of Florida, with particular attention to its funding methodology. Limitations The current study was limited to the theory of equity, without assessments of adequacy, efficiency, or excellence. Equity assessments were limited to horizontal per-pupil equity, wealth neutrality, and taxpayer equity. Vertical equity was not addressed. A macroanalysis of a state system of distributing education resources was included in the study, but not a microanalysis Assessments of the equity of the distribution of resources among districts were made No effort was made to examine the distribution within districts. Delimitations Data were taken from one state and included only one fiscal year, 1992-93, the most recent in which data were available. Fiscal data were additionally limited to those from state and local sources, with federal funding not being addressed.
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The study examined fiscal data from public elementary and secondary schools only. Neither private schools nor higher education organizations were considered. overview of the Methodology 7 The foundation distribution system of the state of Florida was used in the study. Data for the study were taken from the Florida Education Finance Program (FEFP) of the 1992-93 school Year. The FEFP included a foundation basic support program in addition to two unequalized discretionary millage rates, the discretionary millage and the capital outlay and maintenance millage. Mean per-pupil revenues among the districts derived from the foundation program, the discretionary levies, and the capital outlay and maintenance levies were used to analyze the equity of the FEFP distribution. The per-pupil revenues were divided into seven levels of aggregation which included all combinations of the foundation, discretionary, and capital outlay and maintenance revenues. Equity was measured according to three standards. The first was resource accessibility, which provided an assessment of per-pupil horizontal equity. The second was wealth neutrality, using per-pupil assessed valuation as the basis of local fiscal capacity. The third was tax yield, which provided an indication of taxpayer equity. The
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following section includes a summary of the contents of the study Design of the study Chapter 1 has provided an introduction to the study. The nature of the problem was presented as well as the specific research question addressed. Following was the significance of the study as well as its limitations and delimitations and an overview of the methodology. Chapter 2 presents a review of the literature pertinent to the study. This includes a description of the historical development of the theory of fiscal equity as well as a summary of court cases through which the equity of state foundation systems was legally tested. The literature review further includes both a written description of the foundation method of distributing education dollars and a review of previous research studies concerning Florida's foundation distribution system. Chapter 3 includes a description of the research methodology in greater detail than provided above. Chapter 4 includes a discussion of the results of the study while Chapter 5 includes a summary as well as conclusions and implications derived from the study. Notes lRobert Berne, "Equity Issues in School Finance," Journal of Education Finance 14 (Fall 1988), 159. 8
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2 Thomas H. Jones, Introduction to school Finance (New York: Macmillan Publishing Company, 1985), 5; Percy E. Burrup, Vern Brimley, Jr, and Rulon Garfield, Financing Education in a Climate of Change. 4th ed. (Boston: Allyn and Bacon, Inc., 1988), 79-80; James w. Guthrie, Walter I. Garms, and Lawrence c. Pierce, School Finance and Education Policy; Enhancing Efficiency, Equality, and choice, 2nd ed. (Englewood Cliffs, NJ: Prentice-Hall, 1988), 130; David H. Monk, Educational Finance; An Economic Approach (New York: 9 McGraw-Hill, 1990), 35; R. Craig Wood and David C. Thompson, Education Finance Law: constitutional challenges to state Aid Plans--An Analysis of Strategies (Topeka, KS: National Organization of Legal Problems in Education, 1993), 1; David C. Thompson, R. Craig Wood, and Davids. Honeyman, Fiscal Leadership for schools; concepts and Practices (White Plains, NY: Longman Publishing Group, 1994), 53. 3Robert Berne and Leanna Stiefel, The Measurement of Equity in School Finance (Baltimore: The Johns Hopkins University Press, 1984), 13; Burrup, Brimley, and Garfield, 83; Guthrie, Garms, and Pierce, 302; L. Dean Webb, Martha M. McCarthy, and Stephen B. Thomas, Financing Elementary and Secondary Education (Columbus: Merrill Publishing co., 1988), 189; Monk, 36; Robert Berne and Leanna Stiefel, "Equity Standards for State School Programs: Philosophies and Standards Relevant to Section 5(d) (2) of the Federal Impact Aid Program," Journal of Education Finance 18 (Summer, 1993), 95; Wood and Thompson, 18; Thompson, Wood, and Honeyman, 56. 4 Berne and Steifel, The Measurement of Equity, 13; Burrup, Brimley, and Garfield, 83; Guthrie, Garms, and Pierce, 302; Webb, McCarthy, and Thomas, 189; Monk, 37-39; Berne and Stiefel, "Equity Standards," 95; Wood and Thompson, 18; Thompson, Wood, and Honeyman, 56. 5Berne and Stiefel, The Measurement of Equity, 17; Burrup, Brimley, and Garfield, 80-81; Webb, McCarthy, and Thomas, 189; Berne and Stiefel, "Equity Standards," 95. 6 Berne and Stiefel, The Measurement of Equity, 41-42; Guthrie, Garms, and Pierce, 143; Webb, McCarthy, and Thomas, 192; Berne and Stiefel, "Equity Standards," 96-97. 7James Gordon ward and William E. Camp, "An Analytic View of Two Decades of Reform in School Finance: Some comments," Journal of Education Finance 14 (Summer, 1988), 1-6.
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8Guthrie, Garms, and Pierce, 150-152; Webb, McCarthy, and Thomas, 192; Austin D. Swanson and Richard A. King, School Finance: Its Economics and Politics (New York: Longman, 1991), 225; Thompson, Wood, and Honeyman, 45-52. 10 9Arthur W. Stellar, "Implications for Programmatic Excellence and Equity," in van D. Mueller and Mary P. McKeown (eds.), The Fiscal, Legal, and Political Aspects of Elementary and secondary Education (Cambridge, MA: Ballinger, 1986); Burrup, Brimley, and Garfield, 81; Guthrie, Garms, and Pierce, 29. l0Burrup, Brimley, and Garfield, 32; Guthrie, Garms, and Pierce, 28-34; Webb, McCarthy, and Thomas, 192; Monk, 4-11; Swanson and King, 259-278. llBerne, "Equity Issues," 159. 12stephen D. Gold, David M. Smith, Stephen B Lawton, and Andrea c. Hyary (eds.), Public school Finance Programs of the United States and Canada, 1990-91, vol. 1 (Albany, NY: Center for the Study of the States, 1992), 22-23. 13wood and Thompson, 28. 14Thompson, Wood, and Honeyman, 223-224. 15Gold, Smith, Lawton, and Hyrary, 18.
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CHAPTER 2 REVIEW OF THE LITERATURE In Chapter 1 the research question addressed by this study was presented. Specifically, this study dealt with the effects of the moneys raised through local discretionary millage rates on fiscal equity of a state foundation distribution system. This chapter includes a summary of the literature related to the study. The chapter begins with a summary of the development of the theory of educational funding equity, which was introduced in chapter 1 of this study and to which this study was intended to contribute. Subsequently the discussion turns to decisions rendered in the federal and state court systems dealing with the problem of providing equitable systems of education funding in the states. Following this summary of relevant court cases is a discussion of the foundation system for distributing state funds to local school districts. The final section of this chapter includes a summary of previous studies of the equity of the distribution of school funds through the foundation system of Florida, the state from which the data were derived. 11
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12 The Theory of Per-Pupil Funding Equity By its nature, providing an equitable system of funding education requires the state to provide greater financial support to less wealthy local education agencies because such districts do not have access to the same fiscal resources to which the wealthier districts have access. Following is a discussion of the historical development of the theory of equity as it relates to state financial support for public education. With the publication of his monograph in 1906, Ellwood Cubberley was the first modern scholar to discuss the concept of equity as it relates to school finance. 1 Cubberley was the first to develop the concept that the schools of a state should be considered a state system of schools, rather than a series of local systems, in order to foster equitable funding. According to Cubberley, the duty of the state was to equalize the advantages to all school children considering the resources available to the state. 2 Cubberley theorized that the state itself should provide fiscal aid to districts that could not generate revenue equivalent to other areas of the state in order to equalize the educational opportunity throughout the state. 3 According to Cubberley, [A]id should bear some definite relationship to the needs of a community and to the efforts which it makes to provide good schools and to secure the attendance of children in them. 4 George Strayer developed the concept that the state should intervene in the funding of schools in order to
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guarantee a certain minimum, or foundational, level of funding for each child. 5 In collaboration with Haig, Strayer argued that in order to achieve equalization of educational opportunity: [I]t would be necessary (1) to establish schools or make other arrangements sufficient to furnish the children in every locality within the state with equal educational opportunities up to some prescribed minimum; (2) to raise the funds necessary for this purpose by local or state taxation adjusted in such manner as to bear upon the people in all localities at the same rate in relation to their tax-paying ability; and (3) to provide adequately either for the supervision and control of all the schools, or for their direct administration, by a state department of education. 6 Strayer envisioned that each local district provide a level of taxation that would provide funding for a minimally acceptable level of education if applied to the residents in the wealthiest district in the state. The wealthiest district, in applying this tax rate, would raise all the money required to finance the schools within the district's borders. The state would grant each remaining district enough money that, in combination with the funding raised locally, supported this minimally acceptable level of education. 7 Strayer held that the same local tax rate should be exerted throughout the state. In this respect, his conceptualization of local effort differed from that set forth by Cubberley, who believed that local districts should be free to tax at a higher level than other 13
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districts if the citizens of the district so desired. Strayer believed that allowing districts to generate moneys beyond those resulting from the statewide local effort tax rate would have disequalizing effects. 8 Strayer claimed that the "logical conclusion" of equalizing educational opportunity was a full, statewide system of schools. Yet, localization of the financing and administration being strongly grounded in American tradition, Strayer maintained that some degree of local control should be maintained in a state. 9 Harlan Updegraff, writing in the early 1920s, concurred with the early proponents of equity that the state should aid poorer districts more generously in order to provide equal opportunity. 10 Updegraff argued, however, that in addition districts should be rewarded for effort in the sense of the willingness to raise educational revenues through taxation. Equalization funding from the state, according to Updegraff, should be a function of the tax effort put forth by each district. The same effort from two districts would result in the same level of fiscal support for education per funding unit. 11 Updegraff believed that such a system would promote funding equity as well as preserve local control over education. Additionally, such a policy would correct a system in which poorer districts, out of necessity, were 14
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required to exert greater tax effort in order to provide for an acceptable level of education. Through an equalizing system that rewards for tax effort, the state would encourage localities to rise above a certain state mandated foundational level, and therefore with state assistance each district would be in a position to "be its best. 1 2 Henry C Morrison, who like the previously mentioned researchers supported the theoretical ideal of providing equitable funding for education, took the concept a step further by advocating complete statewide funding of public schools. 13 Morrison believed funding inequities emanated from the fundamental flaw of the existence of localized funding of the educational enterprise. Morrison proposed that instead of providing a system of distribution of state funds in inverse proportion to local district needs, as advocated by Strayer, a system by which district organization is bypassed should come into fruition. Thus each student would be provided an equivalent level of funding from revenue generated through state taxation. 14 Under the American ideal of federalism, according to Morrison, the states maintained plenary power over civil matters such as public education, and the local governing organizations such as school districts were simply subdivisions of states Therefore, the stage was 15
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set for state level funding circumventing local control without imparting damage on the American system of governance 15 Morrison argued that revenue for these state funds could come from among four sources, in any combination. These included property taxes levied statewide, state income taxes state taxes on corporations, and income from state school lands or invested school funds. 16 Paul J. Mort, a student of Strayer at Teacher's College, expanded the concept initially developed by Strayer and Haig that the state should establish and help support a foundational level of education for all children 17 Because a foundational level of education should be based on educational need, Mort developed the idea of quantifying educational need and us i ng it as school finance policy According to Mort, the educational need . of a community is regarded as the composite of all of those elements in the community that would affect the cost of the public educational offering demanded by a state program for making available to all children a satisfactory minimum educational opportunity. The relative weighting of each element would be determined by its effect on the cost 18 The state should employ a method through which this need, in terms of resources, is satisfied for each child 16
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in the state. Mort referred to this method as the 11 satisfactory equaiization program 11 19 Mort discussed specific planning for such an equalization program. The classroom, expressed as teacher units, was the cost unit in the plan. Basically, according to Mort, each child would have available the classroom or teacher equipped to the point where a program of satisfactory equalization of educat i on would be met. Each community, in turn, would have sufficient classroom units to appropriately educate children in that community 20 The concept of per-pupil equity specifically as it relates to the foundational state distribution system was developed by Mort throughout the remainder of his scholarly career, 21 as well as by other notable school finance authors For example, Edgar Morphet discussed important elements which should be included in a worthwhile foundation program. 22 All children should be granted an adequate level of education, financed jointly by the state and the respective local districts. The system should promote equality of educational opportunity among students in the state. Local districts should be able to fund schools above the minimum foundational level, properly maintaining a degree of local control over education. Furthermore, according to Morphet, the state should make a 17
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substantial contribution to the foundational level in order that no undue burden would be placed on the local districts. The foundations of the concept of equity were laid by these scholars. With their writings the theory of equity as it relates to education funding developed, and by late 1960s and early 1970s many states had established systems by which the state made corrections for existing inequities. According to data provided by the National Education Foundation Project, by the late 1960s forty-two states used equalization programs to fund schools, seven states employed non-equalizing flat grant distribution systems, and one state, Hawaii, used a system of complete state and federal support. 23 The Strayer-Haig foundation plan was by far the most popular of the equalization plans, with thirty-four states using this method at that time. 24 Although the vast majority of the states had incorporated equalization formulas into the respective school finance systems by the early 1970s, the degree to which these systems were truly equalizing was questionable. In 1972, the President's Commission on School Finance conducted a nationwide study on the equity status of the fifty state programs for school funding. 25 The ratio of maximum to minimum per pupil expenditures ranged from 1.3 to 1 in Hawaii to 56.2 to 1 18
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in Texas. The ratio of the 95th percentile to the 5th percentile ranged from to 1.2 to 1 in Maryland to 5.6 to 1 in Wyoming. The ratio of the 90th percentile to the 10th percentile ranged from 1.2 to 1 in Georgia and West Virginia to 3.0 to 1 in Montana. 26 Clearly, even in the states where the greatest equalization had been accomplished, relatively large disparities in per-pupil financial support existed. Similar results were found in the area of wealth neutrality among the states. The ratio of the maximum to the minimum property valuations per-pupil ranged from 1.7 to 1 in North Dakota to 182.8 to 1 in Kansas. The 95th to 5th percentile ratios ranged from 1.6 to 1 in North Dakota to 9.6 to 1 in New Mexico. The 90th to 10th percentile ratios ranged from 1.6 to 1 in New Hampshire and North Dakota to 6.9 to 1 in New Mexico. 27 It is apparent that the resource accessibility to fund education varied widely among local districts in all the states (excluding Hawaii, which included no local funding of schools}, with some of the variations being extreme. Because of the continued existence of these inequalities the nation"s courts became a significant arena in which greater equalization of support for education was promoted. State school finance systems in various states were challenged in both federal and state 19
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courts, the majority from the early 1970s through the present. These challenges to state distributions of school funds will be discussed in the following section. school Finance Equity court cases A plethora of challenges to state public school distribution systems have been decided in the federal and state court systems Because the purpose of this study is specifically related to distributional equity of the foundation system of public school finance, only those cases which have involved challenges to foundation systems on equity grounds will be discussed. 20 A small number of school finance equity cases have been decided in the federal court system. These cases involved challenges to funding distribution based on the constitutional theory of equal protection clause of the U.S. Constitution 28 The claim usually made was that the system of funding treated students in poorer districts unfairly, or that the distribution system deprived students in the poorer districts, as defined by per-pupil property wealth, of educational opportunity. 29 These cases have been unsuccessful in terms of reforming state funding methodologies to decrease per-pupil funding disparities. The landmark federal school finance equity case was .s.an Antonio y. Rodriguez, 30 which set the tone for school finance decisions in the federal courts. The primary issue was
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21 whether the Texas system of financing public schools was in violation of the equal protection clause due to the fact that children residing in school districts with relatively low property values were provided an education at a lower level of funding than children residing in wealthier districts. Such disparities in funding level allegedly resulted in the deprivation of educational opportunities for these children. 31 The U.S. District Court for Western Texas ruled that the finance system indeed violated the equal protection clause. 32 The court ruled that the funding disparities created a suspect classification of children residing in the poorer districts, and that these children were denied the fundamental right of education because of substandard funding 33 The court had applied the strict scrutiny test, and the state failed to demonstrate a compelling interest for maintaining such a system which violated this fundamental right. The U.S. Supreme Court reversed the decision on appeal. The Court in its decision declined to use the strict scrutiny standard for three reasons. First, the appellees could not demonstrate that any suspect class was disadvantaged by the system. No reason existed to believe that all poor people in the state resided in the districts with lower property values. 34 Second, the Texas foundation financing plan guaranteed a minimum level of education (through statewide funding
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22 supplements) for all children. Therefore, education per se was not denied to any child in the state; some children were simply provided less funding for their education than others. 35 The equal protection clause, according to the Court "does not require absolute equality of advantages. 11 36 Third, the Court ruled that education was not a fundamental right. The Court declared that although education was extremely important to society, it was not the province of the court to pick and choose certain substantive rights (such as education) to call fundamental and thus guarantee equal protection. 37 To be fundamental, such a right must be explicitly or implicitly mentioned in the Constitution. 38 Because education was not a fundamental right and because no suspect class was involved, according to the Court only a rational relationship between the school finance system and state purpose would need to be demonstrated 39 In the Court's view, the Texas foundation system was designed to extend education to all children, and to improve its quality. 40 The Legislature had chosen to facilitate funding of schools largely through local sources to promote local autonomy and control of education, which is strongly grounded in American tradition. 41 Furthermore, no fiscal system was completely non-discriminatory, and having some inequality was not sufficient grounds to strike down the system. 42 Therefore, the Texas foundation system withstood
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23 the rational relationship test, and was declared by the Court to be in compliance with the equal protection clause. 43 Because of the precedent established in the Rodriguez case the state court systems became the primary means of attacking state finance systems on equity grounds. These challenges typically involved allegations of violation of the given state's constitutional equal protection guarantee, the education article of the constitution, or both 44 The overall results of these challenges, in terms of judicial determination of the distributional equity of state finance systems in light of these constitutional provisions, have been mixed. The landmark case for challenges to state school finance distribution methodologies in state court systems was Serrano y. Priest. 45 The allegation was that the disparities in per pupil funding among California school districts (based on relative property values) had resulted in a violation of the equal protection clause of both the California Constitution and the Fourteenth Amendment to the U.S. Constitution. 4 6 The California Supreme Court eventually decided the case. In its decision, the court applied the strict scrutiny test to the state school finance system. The court justified this measure because education was a fundamental right and because a suspect class had been denied this fundamental interest 47 The court ruled that the system failed the strict scrutiny test and violated both constitutions. 48
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24 The court declared "irrefutable" the fact that a suspect class consisting of less wealthy individuals had been discr i minated against due to the nature of the finance system 49 The appellees argued that the system resulted in discrimination against school districts, not a class of individuals. 50 The court, however, ruled that this discrimination affected a class of people residing in these poor districts 51 The court also ruled that education was a fundamental right which should be protected by the equal protection clause of both constitutions. Education, according to the court, was significant for future economic and social success of students. 52 Education was also declared to be necessary for an enlightened citizenry, capable of engaging in fruitful civic and political activities. 53 Therefore, the finance system failed the strict scrutiny standard because the state could demonstrate no compelling interest in maintaining it. 54 One year following Serrano. a decision in the New Jersey court system was rendered concerning that state"s finance distribution system. 55 At issue was the constitutionality of the New Jersey foundation system of funding schools. 56 The Supreme Court of New Jersey eventually decided the case, declaring the foundation system in violation of the equal protection clause of both the New Jersey and the U.S. Constitutions. The court, based on a plethora of expert testimony, determined that a direct relationship existed
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25 between expenditures and overall educational quality. 57 Although New Jersey at the time of the case ranked third in the nation in terms of total expenditure per-pupil for education, disparities among districts were nevertheless large. 58 The court admitted that although it was difficult to determine just how much expenditure per-pupil was enough, clearly in some districts the expenditure was totally inadequate (e.g., based on such factors as conditions of facilities and academic status of students). The court believed some children were definitely receiving an inadequate education. 59 The "thorough" required by the New Jersey Constitution meant something beyond the minimum according to the court. A thorough education therefore was not being provided to every child, and the constitutional mandate was being violated. 60 Furthermore, the fostering of local control of education could not be used to justify a system with huge inequities in per pupil expenditures. Real control was illusory for the poorest local districts that had limited resources available to them. 61 The court applied the strict scrutiny standard to the system and could find no compelling state interest which justified the school finance system. The court expressed doubts that the system could even survive the less stringent rational relationship test. 62 Therefore the court declared
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26 the foundation system in violation of the U.S. Constitution 63 and the New Jersey Constitution. 64 Following Serrano and Robinson, state foundation distribution formulas in many states were challenged in the respective state court systems. Michigan"s system of school finance was challenged in that state's court system, the claim being made that the system was in violation of both the Michigan and the U.S. Constitutions. 65 The U.S. Constitutional issue was disposed of by the court citing Rodriguez as precedent. 66 In deciding the state constitutional issue, the court focused on the relationship between inputs (i.e., available monetary resources) and educational opportunities. 67 The court stated that no evidence had been provided that students in the poorer districts were significantly more deprived of educational opportunity than students in wealthier districts. 68 The court further stated that no proof was available that eliminating per-pupil funding disparities among districts would somehow increase opportunity for students residing in poor districts. 69 The state's constitutional obligation, according to the court, was to provide a basic system of schools for all children throughout the state. The Michigan Constitution did not require equal expenditures for all students as an expression of equal educational opportunity. 70 Therefore the
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27 foundation system of Michigan was upheld as constitutionally valid. The foundation system of Idaho was challenged as violating both the U.S. and the Idaho Constitutions. 71 The challenge was based on per-pupil funding disparities resulting from a heavy reliance on local ad valorem taxation to fund education in Idaho 72 The Supreme Court of Idaho upheld the constitutionality of the finance system. According to the court, availability of funds was a very important factor in determining educational adequacy. Yet, the Court could not declare that smaller expenditure levels resulted in a denial of equal protection. 73 The court further declared that the Legislature was exercising its plenary power in developing and administering a valid system for financing schools. The court would establish itself as a "super legislature" to interfere with this authority. 74 The court found the use of the strict scrutiny test unnecessary in that education was not a fundamental right. 75 The state had as a rational basis for developing and administering the foundation program the fostering of local control of education 76 Therefore, the foundation plan was upheld as constitutional. The constitutionality of the Oregon state foundation system was challenged in that state court system. 77 This challenge was based on the existence of substantial per-pupil spending disparities due to heavy reliance on local wealth
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for funding schools resulting in alleged deprivation of educational opportunity for students living in poorer areas of the state. 7 B 28 The Supreme Court of Oregon upheld the constitutionality of the foundation system. The court did not answer the question of whether education was a fundamental right and therefore subject to equal protection guarantees. 7 9 Nevertheless, the court declared that no child had been deprived access to a minimum level of education even though the educational program offerings available to children varied widely. BO The court agreed that the objective of the finance system was to allow local control over education. While admitting that the lack of adequate resources diminished local control for poorer districts, the court could not conclude that equal protection had been violated because of such diminution. Bl The court also agreed that perhaps other systems of finance could be developed to more adequately equalize per pupil expenditures in education. Yet, the court saw this as no reason to strike down the current system as unconstitutional. The court ruled that the Oregon Constitution did not mandate uniform funding per-pupil across the state. Rather, the state was required to provide a basic level of education to all children. B 2
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29 In West Virginia, the school finance system was declared unconstitutional by the State Supreme Court of Appeals based on both equity and adequacy grounds. The court ruled that the mechanisms for financing the schools denied children a thorough and free education and equal protection, both violations of the west Virginia Constitution. B 3 The court declared education a fundamental, constitutionally protected right in West Virginia. B 4 The court found "broad and comprehensive constitutional inadequacies in the structure and composition" of the entire school system, including its method of finance. B 5 Some districts were "woefully inadequate," though all needed some degree of improvement. B 6 The finance system in particular was declared discriminatory by the court. Funding should have been emphasized at the state level instead of local to eliminate funding disparities based on local wealth. B 7 The system therefore was in violation of the state constitution because a thorough and efficient system of schooling was not being provided. The Ohio Supreme Court declined to apply the strict scrutiny standard in examining the Ohio finance distribution system. BB Finding no fundamental interest involved, only the rational relationship test was applied to the system. B 9 Furthermore, the court ruled that, in deference, the
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constitutionality of legislative acts should be assumed unless a clear violation were evident. 90 30 The state, according to the court, had as a rational purpose promoting local control over education, a tradition dating back to the Northwest Ordinance of 1785 91 Traditionally, the General Assembly had through the years attempted to ameliorate the funding disparities. Although per-pupil funding inequities were real the system was not irrational. 92 Additionally, wide discretion should be given to the General Assembly, and the court should exercise great circumspection and defer to legislative insight in the area of financial provision for education. Although the discretion was not unlimited, the General Assembly had not abused it to the extent that the finance system should be declared unconstitutional. 93 Therefore, the court ruled that the system was not in violation of the Ohio Constitution 94 The Georgia Supreme Court ruled that the state school financing system, despite interdistrict per-pupil funding inequities, was not in violation of the Georgia Constitution. 95 The state financing system, according to the court bore a rational relationship to the state purpose of providing a minimum level of school funding to each student. The court admitted that the finance system had equalizing effects in theory though not in reality. 96 The court also conceded that a positive correlation existed between level of funding and educational opportunity
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(wealthier districts could afford higher instructional salaries, superior curricula, better supplies and plant facilities, etc.) 97 Yet the state finance scheme met the constitutional requirement of providing basic educational opportunities to all children. The court declared that although the state should go beyond the constitutional requirement of providing basic educational opportunities, providing equal expenditures per child was not required of the state. 98 This conclusion was reached because the state Constitution provided great detail about the institution of education but mentioned nothing about equalizing expenditures. 31 The court also declared that although education was vital it was not a fundamental right implicitly or explicitly guaranteed in the Constitution. The U.S. Supreme Court ruling of non-fundamentality in Rodriguez. 99 although not binding with regard to state constitutional issues, provided worthy guidance. Therefore, the strict scrutiny model was not used by the Georgia court. 1 00 The court in its decision made it clear that the Georgia school finance system was a poor one in terms of equity, and urged the Legislature to develop a more equitable system of funding schools Yet the court refused to rule that the system was in violation of the Georgia Constitution. 101 The court also ruled that the state did not violate the adequate education provision of the Constitution. According
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32 to the court, the term "adequate" was not specifically defined in the Constitution. It would have been difficult to determine a judicially manageable standard to determine whether pupils are receiving an adequate education, the court declared, and it would defer to the legislature to assess adequacy The court could not justify declaring the state school financing system inadequate because per-pupil funding disparities existed. 102 The New York Court of Appeals ruled that New York's foundation distribution system did not violate either the New York Constitution or the equal protection clause of the U.S. Constitution. 103 The court in its decision declared that New York had consistently been among the nation's leaders in per pupil school funding. Disparities among districts did exist, and metropolitan areas were hardest hit. However, no claim had been made that any districts provided schooling below state mandated requirements; only the disparities were in question. 104 Because of the complex nature of funding schools, the court declared that it was best left to the Legislature and its staff and the professionals in the executive branch. Though the court was responsible for overseeing compliance with constitutional mandates, no violation was evidenced in this case. 105 The court cited Rodriguez 106 in deciding to use the rational basis test of the school finance system. The state had a rational purpose in allowing local control of
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33 education, and the funding disparities are the result of local wealth differences not legislative actions. 107 Therefore, according to the court, no violation of either constitution had been demonstrated. Furthermore, though the court considered education important, it was not a fundamental right. 1oa The court further found that the state Constitution required only that a system of free public schooling be provided, not equitable per-pupil educational funding. The state had complied with this requirement by establishing minimum standards, both in funding and other educational areas, with which all local school boards must comply. Therefore, the school finance system was ruled not violative of either constitution. The Maryland Supreme Court declared that state's school foundation distribution system constitutionally valid in light of the U.S. Constitution, the Maryland Constitution, and the Maryland Declaration of Rights. 1 09 With regard to the state constitutional issue, the court ruled that the state was not required to provide exact funding levels per pupil. 110 In any event, the state had undertaken through the years to provide increased equalization of expenditures, and the current formula helped ease inequities. The "thorough and efficient" requirement of the state constitution denoted some measure of local control and autonomy in the realm of public
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education. With shared responsibility some measure of funding differentiation should be expected. 111 Citing Rodriguez 112 in dealing with the u.s. 34 Constitutional issue, the court ruled that education should not be declared a fundamental right, and therefore strict scrutiny should not be applied because of non-fundamentality and the nonexistence of a suspect class based on wealth alone 113 Furthermore, no purposeful discrimination by the state was in evidence. 114 Only the rational basis test need be applied, and the state had a rational basis for using the formula to foster local control and autonomy 115 Therefore the state school funding formula was not i n violation of either constitution or the Declaration of Rights. 116 The Arkansas Supreme Court declared that state's school finance system unconstitutional using the less rigorous rational relationship test 117 The court could not find a rational relationship between the disparity of per-pupil funding among districts and the needs of individual districts. At issue in the case was whether the financing system provided by the state foundation plan violated the Arkansas Constitution. The court did not use the strict scrutiny test in this case, and therefore avoided the question of whether education was a fundamental right. The court instead applied the rational relationship test, finding no such relationship between the foundation plan and the individual needs of the
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35 school districts with regard to funding. 118 The court rejected the claim that the purpose of the foundation plan was to promote local control of education, declaring that the provision of more equitable funding would not diminish local control. Furthermore, low levels of per-pupil funding deprived poor districts of effective control of education. 11 9 In Oklahoma, the state school finance system was charged with violating the equal protection clause of the U.S. Constitution and several provisions of the Oklahoma Constitution. 120 The Oklahoma Supreme Court eventually rendered a decision, declaring the system constitutionally valid. The challenge to the system was that the inequitable per-pupil funding levels which resulted from the state foundation plan deprived children in districts with lower property values the opportunity for a good education, a violation of the equal protection clause. 121 The court declared that, under equal protection analysis, legislative acts such as the foundation plan should be considered valid by the courts unless a suspect class had been deprived of rights or if any fundamental right had been violated. 122 Citing Rodriguez. 1 23 the court found that neither of these conditions existed. Furthermore, the allegation was not the complete denial of a free public education to any child, just inequitable per-pupil expenditures. 1 24 The court furthermore declared that the purpose of the plan was to allow local
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control of education and autonomy, and therefore a rational relat i onship existed between the system and a legitimate state purpose. 12s 36 The plaintiffs argued that the U.S. Supreme Court decision in Rodriguez 126 need not apply, that different circumstances existed in Oklahoma than in Texas. The Court claimed that the two state school systems, including the funding plans, were not dissimilar. The Oklahoma court had no reason to rule differently than the U.S. Supreme Court. 127 The plaintiffs charged that the state school financing system was in violation of several provisions of the state constitution. First, because education is specifically mentioned in the Oklahoma Constitution (unlike the U.S. Constitution), it should qualify as a fundamental right. 128 The court, however, ruled that mere mention of education, or any other phenomenon, in the state constitution did not establish it as a fundamental right. 129 Furthermore, providing equitable funding per-pupil was not mentioned in the Oklahoma Constitution. 130 Second, the plaintiffs argued that funding inequities resulted in a violation of the constitutional requirement or uniformity i n the application of laws throughout the state. The court countered that the Legislature had established a foundation plan that applies throughout the state in uniform fashion. 131
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37 The plaintiffs challenged the use of ad valorem taxation in the foundation plan, claiming that the resultant funding disparities violated the equal protection clause of the Oklahoma Constitution. 1 32 The court rejected this argument, saying that the foundation plan had been established to minimize the differences caused by varying levels of district wealth. 133 The court further held that it was obligated to uphold the constitutionality of a given act of the Legislature unless it could be demonstrated that the Legislature acted arbitrarily or capriciously. The Court could find no such violation with regard to the school finance legislation. Thus, the finance system was upheld as constitutiona1. 134 In South Carolina, the foundation distribution system was upheld by the State Supreme Court as valid in light of the South Carolina Constitution. 135 According to the court, the Legislature was constitutionally mandated to provide a system of schooling, but the Legislature had discretion in how to fund the system. Legislative actions such as those relating to funding schools should normally be considered valid by the courts. 136 The plaintiffs also charged that students residing in poor districts were denied equal educational opportunity. The Supreme Court, however, declared that the foundation system included a funding methodology which granted more
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state money to poor districts. Therefore the system was a rational means of equalizing educational opportunity. The Montana foundation distribution system was charged with violating the Montana Constitution. 137 The plaintiffs charged that although the state finance system included interdistrict equalizing provisions, per-pupil funding differences among school districts were as high as eight to one, and thus equal opportunity was being denied. 138 38 The defendants argued that the state foundation plan had been established to foster equal opportunity, and therefore the constitution was not violated. 139 Additionally, according to the defendants, outputs (i.e., assessments based on factors such as standardized test scores and dropout rates) should have been used to measure equal opportunity instead of inputs (i.e., funding) 140 The defendants further argued that although the Constitution established as a goal of the state equal educational opportunity, the document declared local control of schooling as a state goal. With local control naturally disparate per-pupil spending levels occurred. 141 The Montana Supreme Court ruled that the system was in violation of the constitution. The court declared that the state failed to present convincing evidence that outputs rather than inputs signified equal educational opportunity, and that funding disparities were not demonstrably caused by local control of schooling. Furthermore the court ruled that equal educational opportunity was not just an aspirational
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39 goal but a constitutional guarantee. Because of the failure of the state to equalize educational expenditures (due in part to the inadequate funding of the foundation program) the state had failed to provide equal educational opportunity for all children. 142 The Texas foundation distribution system was charged with violating the Texas Constitution based on huge differences in the property wealth of school districts. 143 Because 50 percent of school funding statewide was derived from local sources and because localities relied heavily on ad volarem taxation, wide school funding disparities resulted. A 700 to 1 ratio in property value existed between the wealthiest and poorest school districts, while the per pupil spending gap was $19,333 to $2,112. 144 The Supreme Court of Texas declared the school finance system unconstitutional. The court stated that the amount of money spent on pupils had a significant impact on educational opportunity. Pupils residing in poor districts were in a cycle of poverty which deprived them of educational opportunity. These poor districts, despite normally taxing at a higher rate, still raised less revenue than the wealthy districts, thus giving their schools a reputation for inadequacy. Industry, a key to increasing local wealth, was not attracted to localities with high tax rates and inferior schools. 145
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The court admitted that the Texas Legislature had through the years attempted to lessen the interdistrict funding disparities through the Foundation School Program (FSP). Although the FSP was designed to provide more state 40 money to poorer districts, not enough moneys had been provided to guarantee minimum funding. The court declared that the constitutional mandate of the state had not been met by the FSP. 146 Much of the court's discussion revolved around the concept of efficiency as found in the state constitution. The court declared that determination of efficiency was not necessarily the exclusive realm of the political system and therefore outside judicial control. The constitution did not give exclusive discretion to the legislature for determining what is efficient. Although "efficient" was not specifically defined in the constitution, a standard was provided for the courts to use to determine whether the constitution had been violated. The court had the constitutional duty to determine whether the legislature was fulfilling its constitutional duty 147 The state had argued that "efficient" meant simple and inexpensive. The court found no evidence of this claim. According to the court, for the school system to be efficient districts should have similar revenue available to them, providing all children with equal educational opportunity.
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This was not the case, and therefore the school system was not financially efficient. 14B 41 In Kentucky the school finance system, which included a foundation as well as a guaranteed yield component, was challenged, the charge being that large school funding disparities among Kentucky districts violated both the U.S. and Kentucky Constitutions. 149 The Kentucky Supreme Court declared the finance program, as well as the entire state public school system, in violation of the Kentucky Constitution. The high court in its decision did not condemn the system in light of the U.S. Constitution, declaring that because the educational system had been ruled in violation of the Kentucky Constitution an analysis of U.S. Constitutional issues was not necessary. 1so The litigation revolved largely around the concept of efficiency. The representatives of the state argued that because the Kentucky Constitution required the Legislature to provide an efficient system of schools, the General Assembly, not the courts, was the organization responsible for determining whether the system was indeed efficient. The court, however, ruled that it had the constitutional authority to review the legislation which established the school finance system to determine its constitutionality. Therefore, the court could pass judgment on the efficiency of the state"s school system, and thus the finance system
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supporting it, because efficiency was required by the state Constitution, 151 42 The high court agreed that efficiency, to a large degree, referred to substantial uniformity of resources being applied throughout the school system, resulting in substantial equal opportunity for a good education. The court relied on the testimony of experts who claimed that a significant positive correlation existed between level of expenditure and overall quality of education, and that students who were provided lower levels of funding were prone to receiving a lower quality education. These experts presented data showing that districts with low per-pupil expenditures had more restricted curricula and lower overall achievement test scores 1 52 Therefore, the court ruled that an efficient system of common schools had not been provided because of substantially different levels of school funding among districts throughout the state. Because of heavy reliance on local resources to fund the public schools and the resultant per-pupil expenditure differences based on relative local property values, the General Assembly had created an inefficient educational system. The Supreme Court agreed that although the General Assembly had in recent years passed legislation which provided a greater degree of equalization of funding among districts, huge per-pupil disparities among districts still existed at the time of the case. 153
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In summary, the challenges to school foundation distribution methodologies in state courts have met with mixed success. All of the cases discussed dealt specifically with the equity effects of state foundation formulas for distributing school funds. The next section includes a discussion of the theoretical framework of the foundation system of school finance as well as examples of state foundation systems which provide a funding component for equalizing local discretionary revenues. Foundation Method of Financing schools 43 A foundation program of financing education is one in which the state and local districts contribute jointly to the financing of education is such a way that each child is provided a minimum educational program. In order to accomplish this for each student, the foundation program is based on the ability of districts to pay for this minimum educational program 154 In other words, the level of state support varies inversely with local wealth, thereby providing each district a foundation of fiscal support for educational programs. 155 Under a foundation system, theoretically, the poorest district of the state should be able to financially support the appropriate level of education for each student to the same degree as the wealthiest, given the same amount of
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44 taxing effort. Thus, both per-pupil as well as taxpayer equity are recognized with this distribution system. The state under a foundation system generally establishes a minimum local property tax rate which all districts must pass in order to receive state funding 156 Additionally, a minimum base expenditure for each district is obtained due to state support. 157 Theoretically, beyond the foundation level local districts are able to provide funding to finance additional programs or services above and beyond the foundation level within the parameters established by state constitution or statutes. Such additional funding may cause disequalizing effects in the system overall 158 The foundation plan includes a legislatively determined minimum program from which a local share, based on legislatively determined tax rate is subtracted The remainder is the amount of support from the state necessary to finance such a program. 1 59 Operationally, the amount of state aid is determined as follows: Si= (Pix Fstate) (Vali x rstate) where Si is the state aid to the ith district, Pi is the number of students (as calculated in the state) in the ith district, Fstate is the foundation level as established by the state, Vali is the assessed valuation of property for the
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45 ith district, and rstate is the tax rate set by the local district. 160 The foundation amount established by the state is multiplied by the the number of pupils to produce the total foundation funding for that district. From this product is subtracted the amount the district is required to contribute, based on the local tax rate and the total assessed valuation for that district. The difference between the total foundation funding level and the amount contributed by the district is the amount of state aid to that district. Currently thirty-eight states use some modification of a foundation program to support public education. 161 Such a funding program has as a rationale the provision for each child in the state a foundational level of education whether the child resides in a relatively wealthy local school district or a poorer one. 162 Yet, despite this recognition by states to take an active funding role in order to equalize to a minimally acceptable level for all children, nearly every one of these states allows local districts to apply locally determined millage rates in order to levy funds above the foundation level guaranteed by the state. 163 Although the states impose certain limitations and restrictions on the amount and use of these additional funds, the effects may nonetheless be disequalizing. Some states that fund public schools through a foundation formula employ a two-tiered system, by which the basic program includes the equalization foundation program,
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46 and additional discretionary funds levied by districts are separately equalized by the state. 164 The second level is equalized through a resource accessibility program, either a guaranteed tax base (GTB) or guaranteed yield (GTY). A brief discussion of the operationalization of typical GTB and GTY programs is provided followed by a discussion of the distribution systems of the states that at the time of this writing use or have recently used a GTB or GTY to augment a foundation formula. The GTB and GTY systems are similar to the foundation plan in that all include equalizing educational opportunity through state support in inverse proportion to districts' ability to pay. 165 Unlike a foundation state, a state using a GTB or GTY system does not establish a minimum foundational level of educational support and a minimum tax rate to be levied by districts. Rather, the levels of support are locally determined 166 Thus, the GTB and GTY formulas include equal access to resources, rather than the minimum funding level included in the foundation program. 167 The GTB plan operates on the assumption that all districts should have access to the same tax base wealth per pupil. The state establishes a guaranteed tax base, and the state simply provides each district sufficient funding that, when combined with local funds, is equivalent to funding that would be raised given the guaranteed tax base. The local districts are allowed the discretion to determine local
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47 expenditures as well as the local tax rate. 168 The GTY is similar to the GTB except that the state sets a tax yield level for all property in the state rather than a tax base. 169 The GTB and GTY have identical formulas. The formulas are mathematically expressed as follows: Si = (Pi) (Expi) [1 (C x Adj Val i)] where Si is the state aid to district i, Pi is the number of students as calculated by the state in district i, Expi is the dollar per-pupil expenditure set by district i, c is the state share percentage factor, and Adj.Val.i is the ratio of assessed valuation per-pupil for district i compared to that of the average assessed valuation for all districts. 170 This method is equitable in terms of both per-pupil funding and taxpayer effort. Every child is guaranteed a certain level of funding commensurate with his or her educational need given the level of tax effort exerted in the local school district. Each mill of tax effort results in the same levy per pupil, thus promoting equity among taxpayers. Several states currently use or have recently used a funding scheme which involves a foundation component in combination with a GTB or GTY model. In Georg i a, for example, the Quality Basic Education (QBE) foundation program is supplemented by a GTB component Under the QBE, state aid
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48 to a district is a product of the weighted pupil count times the guaranteed financial support base minus the local fair share, which is the local contribution required for participation in the foundation program. 171 The local contribution is based on a state mandated millage rate applied to assessed property equalized at 40 percent of market value, or a rate which would generate 50 percent of the district's foundation amount, whichever is smaller. 172 The GTB component is available only to districts below the 90th percentile in terms of property wealth per-pupil that levy taxes above the state mandated millage rate. For additional mills above the state mandated level, the state pays the difference between the amount actually generated and the amount that would be generated by applying the millage rate to the assessed value of property in a district at the 90th percentile 173 In Montana, a foundation program is supplemented by a GTB component. 174 The foundation level of support is variable according to categories based on average number belonging (ANB), which represents enrollment. The foundation level thus increases with ANB. The state provides funding for this foundational level per ANB category after subtracting a portion which is raised at the county level. No equalization funds must be provided by local districts themselves with the exception of elementary districts with fewer than ten ANB
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which are not classified as isolated. These districts must raise 50 percent of the foundation amount. 175 49 Under the GTB component districts may levy additional mills for the general fund and counties for the teacher retirement fund. The state guarantees a yield equivalent to the average mill yield for each of these permissive mills. 176 Oklahoma public schools are financed by a foundation program supplemented by the Salary Incentive Aid, which is comparable to a GTY supplement. Foundation aid for each district is determined by multiplying a legislatively established Base Foundation Support Level by weighted Average Daily Membership (ADM). State foundation aid is determined by taking this product and subtracting 15 mills times the assessed valuation of the district from the previous year plus a 4 mill county levy and other minor adjustments. 177 Districts may further apply millage rates above the fifteen mill foundation portion for the Salary Incentive Aid portion component, in which the state provides funds to assure a guaranteed yield. State Salary Incentive Aid is determined by multiplying an incentive aid guarantee by the district's ADM then subtracting the number of additional mills times the assessed valuation of the district. 178 In Kentucky the state provides GTY funding to augment the state foundation distribution system. A certain per pupil dollar amount is guaranteed under the foundation portion of the state funding program. The state grants each
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50 district the difference between what was raised through application of a state mandated millage rate on assessed valuation of local property and what was required to meet the aggregate foundation per-pupil funding level. 179 Districts are permitted to exceed this minimum foundational level, and those that chose to do so are provided matching funds from the state not to exceed 15 percent of their entitlement to ensure a minimum yield. The revenue obtained through this additional levy is equalized at 150 percent of the average statewide per-pupil property assessment. 180 Districts are permitted to increase financing up to an additional 30 percent without a matching grant from the state. 181 A three-tiered finance system used in Texas was recently invalidated by the Texas Supreme Court. 182 However, a brief discussion of the system as it existed prior to its invalidation by the court will be provided to exemplify the operationalization of foundation distribution systems augmented by GTB or GTY components. The Texas system included a foundation, a GTY and an unequalized component. With Tier I, the foundational component, the state granted a district the difference between the amount required to fund each student's education at a certain foundation level and what was actually levied locally through application of a state mandated millage rate against assessed valuation of local property 183 The state under Tier II ensured that for any district that chose to tax
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51 above the foundation millage rate a certain dollar level per pupil for each additional cent of tax rate, up to a maximum rate of taxation. 184 Under Tier III additional millage rates above the guaranteed yield band were permitted but not matched by state funds. 185 The present study included data from the foundation distribution system of the state of Florida for fiscal year 1992-93. Florida schools were funded through a foundation system, although the state did not equalize dollars raised through application of the discretionary or capital outlay and maintenance millage rates. The degree of disequalization caused by the revenues raised through the application of these millage rates was the focus of the present study. The following section includes a review of previous equity studies of Florida's public education funding system. Previous Florida school Finance Equity studies This study focused on equity aspects of the foundation method of public education finance. The foundation plan of the state of Florida, the Florida Education Finance Program (FEFP), was chosen for the study. The following discussion includes a summary of previous equity studies related to the FEFP. Vaughan examined the equity aspects of the FEFP as part of a six state study of the effects of school finance reform on minority and poor students. 186 Vaughan addressed two
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52 research questions which are specifically relevant to the present study. The first included the extent to which inequalities in the distribution of educational revenues existed prior to and after the implementation of the FEFP. The second included the extent to which the level of revenues available for education were related to district wealth before and after implementation of the FEFP. Vaughan examined fiscal data for the 1972-73 school year, prior to the implementation of the FEFP, and the 1973-74, 1974-75, and 1975-76 school years, after FEFP implementation. 187 Vaughan's conclusion with regard to distribution of per pupil revenues was that the FEFP was relatively equitable. The vast majority of Florida's public school pupils fell between the tenth and ninetieth percentile of the district mean state and local revenue per pupil. The range, restricted range, and federal range ratios of state and local per-pupil revenue among districts were all relatively low after FEFP implementation. Although the coefficients of variation of local revenue per-pupil were relatively high, they were lower after FEFP implementation than before. 188 In the area of fiscal neutrality, Vaughan found a strong relationship between local wealth and local per-pupil revenue, with the effect increasing in strength across the four years being studied. A significant relationship also existed between local wealth and state and local revenues per pupil. Although the relationship was smaller after the
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implementation of the FEFP, it was nevertheless significant. Vaughan concluded that the FEFP was not very wealth neutral, although greater wealth neutrality was evident in Florida after the implementation of the FEFP. 189 53 Carroll and Park conducted equity analyses for five states, including Florida. 190 The intent of the Florida portion of the study, which was a follow-up to a similar study conducted by Carroll in 1979, 191 was to compare the equity of the Florida state distribution system before the current finance formula (FEFP) with the distribution which existed prior to implementation. Included in the study were fiscal comparisons made for the 1972-73 school year (before the FEFP) against the 1975-76 school year (after FEFP implementation). These comparisons were made in terms of instructional expenditures as well as revenues at six levels of aggregation These included general revenues not including Racing Commission funds, general revenues including Racing Commission funds, general revenue plus PL 874 revenues, local plus state revenues, local plus state plus PL 874 revenues, and total revenues. 1 92 Carroll and Park found, through a series of regression equations significant relationships between wealth, based on assessed valuation, and per-pupil revenues at all levels of aggregation, both before and after the implementation of the FEFP. 193 Additionally, a significant relationship was found
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54 between instructional expenditures and wealth both before and after implementation. 194 Carroll and Park found no significant relationship between household income and revenues and instructional expenditures per-pupil before the FEFP, yet a significant relationship after implementation. 1 95 The implementation of the FEFP resulted in a weakened relationship between a community's tax effort and the availability of school revenues as well as instructional expenditures. 196 Carroll and Park concluded that in terms of both per pupil revenue availability and instructional expenditures, widened disparities resulted after implementation of the FEFP. The new program became less fiscally neutral, the decline being attributed to the cost adjustment factor included in the formula 197 The overall conclusion reached by Carroll and Park was that the reform benefitted larger and more urban districts more readily than slightly smaller and less urban ones. The greatest benefit reached the less poverty prone school districts. 198 Alexander and Shiver studied the equity of the distribution of school funds in Florida, comparing the equity that existed before FEFP implementation to equity after implementation. 199 Data from the 1970-71 and 1971-72 school years, before the FEFP, and the 1974-75, 1976-77, 1978-79, and 1980-81 school years, after the implementation of the FEFP, were used in the study.
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55 Alexander and Shiver studied two levels of aggregation. The first included total state and local per-pupil revenues and the second the foundation funds per-pupil. Each level of revenue was studied in light of several equity related statistics. In the area of total per-pupil revenue, an increase in both the range and the restricted range of the distribution was evident. The standard deviation of the distribution doubled during the years of the study, while the coefficient of variation remained virtually the same. 200 In the area of foundation funds per pupil, the distribution range quadrupled from 1970-71 to 1980-81, while the restricted range nearly quadrupled. Both the standard deviation and the coefficient of variation increased between 1970-71 and 1980-81 in the area of foundation funds per pupil. 201 The Gini coefficients increased overall after the implementation of the FEFP, both in terms of total state and local revenue per pupil and foundation funds per pupil. These coefficients demonstrated a decreased level of equity by 1980-81. 202 Alexander and Shiver conducted correlational analyses between the two levels of revenue and seven independent variables which were claimed to provide indication of wealth. 203 The authors argued that increased positive correlations between five of the independent variables and total revenue and largely increased positive correlations
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56 between assessed value per-pupil and foundation funds per pupil as well as personal income per-pupil and foundation funds per-pupil implied that the equalization established prior to the FEFP had not been maintained by the FEFP. 20 4 The overall conclusion of Alexander and Shiver based on the analysis of these data was that greater equity had not been achieved with the implementation of the FEFP. 205 Stark, Honeyman, and Wood examined equity aspects of the FEFP in a study specifically related to the effects of the Florida Lottery on public school financing in the state. 20 6 The study included two basic analyses. The first was the degree to which the lottery funds distributed through the FEFP (approximately 67 2 percent of total lottery funds provided to public schools in the state) were used to substitute for existing sources of school funding during the 1989-90 school year. The second analysis, the one relevant to the present study, included an examination of the remaining lottery funds, those distributed through special allocations rather than the FEFP itself. Specifically, this second analysis dealt with whether these lottery funds not distributed through the FEFP had an effect on the equity of the distribution of public education funds in the state. Three levels of aggregation were used in the analysis. The first included funds distributed through the FEFP through which the degree of equity of the FEFP itself could be determined. Second, the FEFP funds plus
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57 special allocations from the state's general revenue fund not included in the FEFP. Third, the FEFP funds, special allocation funds, and lottery funds not distributed through the FEFP. 207 The boxplots showed similarity in variation of distributions for the first two levels of aggregation, with increased variation with the introduction of lottery proceeds. Both the range and the restricted range demonstrated decreased level of equity when moving across the levels of aggregation. 208 The federal range ratio, though it increased across the levels of aggregation, demonstrated that the Florida system was equitable. 209 The variance, standard deviation, and coefficient of variation demonstrated cumulatively disequalizing effects across the levels of aggregation. The relative mean deviation, on the other hand, indicated cumulatively increased equity effects. 210 The Gini coefficient for the FEFP alone, the aggregation level pertinent to the present study, was calculated at .00916, demonstrating a great deal of horizontal equity in the system. Interestingly, the Gini coefficients were reduced to .00261 and .00380, respectively, across the other two levels of aggregation. 211 Likewise, the McLoone Index of 97545 indicated a large measure of equity in the FEFP distribution The McLoone
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Indexes were slightly smaller, .97185 and .97283, for the other two levels of aggregation 212 58 The results of the Gini Coefficient and McLoone Index computations demonstrated that, at least in the 1989-90 school year, the FEFP provided an equitable system of distributing school funds. The study did not, however, address the equity effects of the discretionary and capital outlay and maintenance millage levies. These effects, for the 1992-93 school year, were addressed in the present study. O'Loughlin, Wood, and Honeyman examined the equity of the distribution of FEFP dollars, most specifically looking at the effects of the revenues provided in the sparsity supplement of the formula on per-pupil equity. 213 The data were based on the 1990-91 FEFP calculation, not including federal distributions or capital outlay or debt service funding. In the O'Loughlin, Wood, and Honeyman study, four elements were studied with the cumulative equity effects of each element being examined. These included the foundation program, program supplements, the discretionary local levy, and categorical and special allocations. 214 Within each element the additional revenues resulting from the sparsity supplement were examined to determine the equity effects of this particular feature of the FEFP. 215 The overall results were that the dispersionary measures (range, restricted range, federal range ratio, variance,
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59 standard deviation, coefficient of variation, McLoone index, and Gini coefficient) demonstrated a cumulatively disequalizing effect of the FEFP across the four elements without the sparsity supplement, and an increased disequalizing effect across the four elements in all measures except the McLoone index and the Gini coefficient when the revenues provided the sparsity supplement were included. A disequalizing trend occurred across the four elements for school districts below the median when sparsity supplements were included The Gini Coefficient demonstrated an equalizing trend across the four elements when the sparsity revenues were included. 216 With regard to the wealth neutrality measures (correlation coefficient, coefficient of determination, and slope of the regression), a cumulatively increased association between wealth per-pupil per district and per pupil revenues resulted in the formula without taking into account the sparsity supplement. With the inclusion of the sparsity supplement revenues, a cumulative decrease in the strength of association of the two variables occurred. 217 The overall conclusion was that the basic part of the FEFP was relatively equitable, but the addition of supplements, discretionary dollars, and categorical supplements had disequalizing effects on the distribution of education dollars, with the most pronounced effect being that of the discretionary levy. Additionally, the distribution of
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60 dollars bore a strong inverse relationship to the relative property wealth of the district. The sparsity supplement had the effect of reducing this relationship. 218 O'Loughlin, Wood, and Honeyman demonstrated through this study that the FEFP distributed school funds in an equitable fashion in the 1990-91 school year, with the levies generated from application of the discretionary millage rates having slightly disequalizing effects in light of the overall system. The study did not examine the effects of the equity of the FEFP specifically related to the capital outlay and maintenance millage, which coupled with the discretionary levy was the focus of the present study. Currie examined the equity of resources for capital outlay in Florida, part of which included assessments of both the FEFP and revenues derived from the capital outlay and maintenance millage rate. 2 1 9 Using 1988-89 data, Currie examined four levels of funding. The first included FEFP operating expenditures, which consisted of the net FEFP allocation, the seventh period allocation, prior year adjustments, and the required local effort. The second and third levels consisted of the total dollar value of state capital outlay funding and the total dollar value of local capital outlay funding, respectively. The fourth and final level included the combination of state and local capital outlay funding. 220
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61 The results of the examination at the first level, the ~EFP, and the third level, local capital outlay funding, were of interest in the context of the present study. Results of the examination of the equity of the FEFP element provided evidence of the relative equity of the foundation system as it existed during that fiscal year. The third level included an equity assessment of the revenues generated through application of the local capital outlay and maintenance millage rates Although this level was more broadly defined to include other local sources of capital outlay financing, confounding the capital outlay and maintenance levies with other local sources, examination of the results provided insight for the present study. The levies generated through application of the discretionary millage rates were not examined in the Currie study. The FEFP level of funding demonstrated the greatest degree of equity among the four levels studied in terms of horizontal equity measures. The per-pupil range, restricted range, interquartile range, and federal range ratio were calculated at $368.65, $305.15, $143.03, and .13, respectively. 221 The standard deviation, coefficient of variation, and relative mean deviation per-pupil were $91.79, .04, and .03, respectively. 222 The McLoone Index of .97 was an indication that the distribution of funds to districts below the median was nearly perfectly equitable. 223
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62 In the area of wealth neutrality, the Gini Coefficient of .01 for the FEFP level was an indication of nearly perfect equity. 224 The correlation coefficient between local assessed valuation of local property and expenditures per-pupil was .42 for the entire distribution and .49 for the distribution within a 95 percent confidence interval around the mean value. The resultant coefficients of determination were .18 and .24, respectively. 22 5 The author suggested that a strong relationship between wealth and FEFP did not exist. 226 The results of the horizontal equity measurements of the local capital outlay funding level indicated less equitable distribution than the FEFP. The per-pupil range, restricted range, federal range ratio, and interquartile range were calculated at $886.59, $731.55, $85.11, and $310.32, respectively. 227 The standard deviation, coefficient of variation, and relative mean deviation were calculated at $217.49, .85, and .70, respectively. 228 The McLoone Index was calculated at .67 for the distribution below the median. 22 9 The results from the wealth neutrality measures demonstrated a less equitable distribution from the local capital outlay sources than from the FEFP. The Gini Coefficient was calculated at .19. 230 The correlation coefficient between local assessed valuation per-pupil and local capital outlay revenues per-pupil was .72 for the entire distribution and .79 for the distribution within a 95 percent confidence interval around the mean. The associated
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63 coefficients of determination were .52 and .63, respectively. 231 The author suggested that major violations of wealth neutrality in this area existed. 232 Again, the revenues resulting from the application of the capital outlay and maintenance millage rates were confounded with revenues from other local sources of capital outlay financing. Nonetheless, the capital outlay and maintenance levies contributed to the relatively inequitable distribution as determined in the Currie study. In summary, though various elements of the equity of distribution aspects of the FEFP have been studied, a need existed to examine the equity effects of the distributions resulting from the discretionary and capital outlay and maintenance levies. The present study represents an exhaustive analysis of this research question. conclusion This chapter began with a discussion of the historical process by which state governments assumed more active roles in providing financial support to school districts in recognition of the need to provide less wealthy localities larger state grants to make up for smaller tax bases. This ideal of state support was developed by the early scholarly work of school finance theorists who, writing in the early half of the twentieth century, advocated state interventions in order to foster per-pupil funding equity. In the latter
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64 half of the twentieth century, state distribution methodologies were tested in the American federal and state judicial systems to determine if state governments were providing all students in the state an equivalently adequate level of education. The results of these cases in terms of school finance equity reform were mixed. Following was a discussion of the foundation system of funding schools, the most common distribution system currently in use. Finally, previous research studies concerning equity effects of this Florida funding system were discussed. The purpose of this study was to analyze the effects of the discretionary millage levies on the fiscal equity of a foundation system. The next chapter includes a presentation of the specific methodology by which these effects were examined. Notes 1 Ellwood P. Cubberley, School Funds and Their Apportionment {New York: Columbia university, 1906). 2rbid., 17. 3rbid., 4. 4rbid. 5George D. Strayer and Robert M. Haig, The Financing of Education in the state of New York, vol. 1 {New York: Macmillan, 1923). 6rbid., 174. 7rbid., 174-175. 8rbid., 175-176.
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65 9Ibid., 176. lOHarlan Updegraff, Rural school survey of New York State: Financial Support (Ithaca, NY: The Joint Committee on Rural Schools, 1922). llibid. 136. 12Ibid., 110-115. 13Henry c. Morrison, School Revenue (Chicago, IL: University of Chicago Press, 1930). l4Ibid., 195. 15Ibid., 208-214. 16Ibid. 200. 17 Paul R. Mort, The Measurement of Educational Need (New York: Teachers College, Columbia University, 1924). l8Ibid., 1. 19Ibid., 6. 20Ibid. 8-11. 21see, e.g., Paul R. Mort, state support for Public Schools (New York: Teachers College, 1926); Paul R. Mort, state support for Public Education (Washington, D.C.: The American Council on Education, 1933); Paul R. Mort and Walter c. Reusser, Public School Finance (New York: McGraw-Hill Book Company, Inc., 1941); Paul R. Mort, Walter C. Reusser, and John w. Polley, Public school Finance: Its Background, Structure, and Operation (New York: McGraw-Hill Book Company, Inc., 1960). 22Edgar Morphet, "Characteristics of State Support Programs," in R.L Johns (ed.), Problems and Issues in school Finance (New York: National Conference of Professors of Educational Administration, 1952). 23Roe L. Johns and Richard G. Salmon, "The Financial Equalization of Public Schools Support Programs in the United States for the School Year 1968-69," Status and Impact of
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Educational Finance Programs (Gainesville, FL: National Education Finance Project, 1971), 122. 2 4 rbid. 25president's Commission on School Finance, Reyiew of Existing state school Finance Programs (Washington, D.C.: United States Government Printing Office, 1972). 26rbid 13 27rbid. 14. 28u.s. Const. amend. XIV. 66 29Julie K. Underwood and Deborah A. verstegen, "School Finance Challenges in Federal Courts: Changing Equal Protection Analysis," in Julie K. Underwood and Deborah A. verstegen (eds ), The Irot>acts of Litigation and Legislation on Public School Finance (New York: Harper & Row, 1990), 177. 30 san Antonio Independent school District v, Rodriguez. 4 11 U S 1 (1973). 3 1 rd. at 17 32 san Antonio Independent school District v, Rodriguez. 337 F.Supp 280 33rd. at 282. 34 san Antonio, 411 u.s. at 17-23. 35rd., 23-24. 36rd. at 24. 3 7 rd at 33 38rd., 33 34. 39rd. at 40. 40rd. at 45. 4lrd., 48-50.
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42rd., 53-54. 4 3rd. at 55. 67 44william E. Sparkman, "School Finance Challenges in State Courts," in Julie K. Underwood and Deborah A. Verstegen (eds.), The Impacts of Litigation and Legislation on Public School Finance (New York: Harper & Row, 1990), 193. 45487 P.2d 1241 (1971). 46rd. at 1244. 47rd. at 1250. 48The case was decided prior to the precedent established by Rodriquez of using the rational relationship standard in light of alleged violation of the Fourteenth Amendment equal protection clause. 49 serrano. 487 P.2d at 1250. 50rd., 1250-1252. 51rd., 1252-1253 52rd., 1255-1256. 53rd. 1256-1259. 54rd., 1259-1263. 55 Robinson y. Cahill, 287 A.2d 187 (1972). 56rd., 189-190. 57rd., 200-205. 58ra., 199-200. 59rd. at 205. 60rd. at 211. 61rd., 212-213. 62rd. at 214.
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63The case was decided prior to the precedent established by Rodriguez of using the rational relationship standard in light of alleged violation of the Fourteenth Amendment equal protection clause. 64 Robinson. 287 A.2d at 217. 65 Milliken V, Green. 212 N.W.2d 711 (1973). 66rd. at 714. 6 7 rd. at 716. 68rd., 716-718. 69rd. at 719. 7 0rd. at 720. 71 Thompson Y, Enkelking, 537 P.2d 635 (1975). 72rd., 638-640. 73rd., 641-642. 7 4rd. at 642. 75rd., 642-645. 76rd., 646-653. 77 olsen y, state. or. 554 P.2d 239 (1976). 78rd., 140-142. 79rd., 144-145. 80rd., 145-146. 8 1 rd. at 147. 8 2 rd. at 148 83pauley V, Kelley. 255 S.E.2d 859 (1979). 68
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84rd. at 878 85rct. 86rct 87rd., 878-883. 88 Board of Education of city school District, etc, v, Walter, 390 N.E.2d 813 (1980). 89rct at 819. 90rct. 91rct. at 820. 92rct. at 821. 93rct., 823-826. 94rct. at 822. 95 McDaniel v. Thomas, 285 s.E.2d 156 (1981). 96rct. at 159 97rd., 160-161. 98rct., 164-165. 99 san Antonio. 411 u.s 1 (1973). lOOMcDaniel, 285 S.E.2d at 167. l0lrct at 168. 102rd., 165-166. 69 103 Board of Education, Leyittown, etc, v, Nyquist. N.Y., 439 N.E.2d 359 (1982). 104rd. at 363. 105rd 363-364.
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106san Antonio. 411 u.s. 1 (1973). 107Leyittown, N.Y., 439 N.E.2d at 364-365. 108ra. at 368-369. 109ttornbeck v, somerset county Board of Education. 458 A.2d 758 (M.D. 1983). ll0ra. at 776. lllra., 776-780. 1 1 2san Antonio. 411 u.s. 1 (1973). 113ttornbeck, 458 A.2d at 787-788. 114ra., 782-783. 115ra., 786-787. 116ra., 788-790. 70 117pupree v, Alma school District no. 30. 651 s.w.2a 90 (1983). 118ra., 92-93. 119ra. at 93. 120pair school Finance council of Oklahoma. Inc. v, Oklahoma. 746 P.2d 1135 (1987). 121ra. at 1138. 122ra. at 1144. 123san Antonio. 411 u.s. 1 (1973). 124Fair school Finance, 746 P.2d at 1144-1146. 12sra., 1146-1147. 1 2 6san Antonio. 411 u.s. 1 (1973). 127 Fair school Finance, 746 P.2d at 1147.
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128rd. at 1148. 129rd., 1148-1149. 130rd., 1149-1150. 131rd. at 1150. 132rd., 1141-1142. 133rd., 1142-1143. 134rd. at 1150. l3 5 Richland County Y, Campbell, 364 S.E.2d 470 (S.C. 1988) 136rd., 471-472. 137ttelena Elementary school District No, 1 v, state of Montana. 769 P.2d 584 (1989). 138rd. at 686. 139ra. at 689. 140rd. at 690. 141rd. at 690. 142rd. at 691. 143Edgewood Independent school District v. Kirby. 777 S.W.2d 391 (1989). 144rd. at 392. 145rd. at 393. 146rd. at 392. 147rd. at 394. 148rd., 394-398. 71
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149 Rose v. The council for Better Education, Inc .. 790 S.W.2d 186 (1989). 150rd. at 215. 151rd 208-209. 152rd. 210 213. 153rd at 213. 72 154R. Craig Wood and David c. Thompson, Education Finance Law: constitutional Challenges to state Aid Plans: Ao Analysis of Strategies (Topeka, KS: National Organization of Legal Problems in Education, 1993), 25. 155David C. Thompson, R. Craig Wood, and Davids. Honeyman, Fiscal Leadership for schools: concepts and Practices (White Plains, NY: Longman Publishing Group, 1994), 220. 156rbid., 221. 157wood and Thompson, 26. 158Thompson, wood, and Honeyman, 223. 159rbid. 221. 160rbid. 222. 161stephen D Gold, David M. Smith, Stephen B Lawton, and Andrea c Hyary (eds.), Public School Finance Programs of the united states and Canada, 1990-91. vol. 1 (Albany, NY: Center for the Study of the States, 1992), 18. 162rbid., 22-23. 163rbid. l6 4 Deborah A verstegen, School Finance at a Glance (Denver CO : Education Commission of the States, 1990), 2. 165 Thompson, Wood,and Honeyman, 225 166rbid., 225-226.
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167Ibid. 226. 168Ibid., 228. 169Ibid., 229. 17 0Ibid., 229-230. 171Ga. Code 20-2-165(b). 172Ga. Code 20-2-164. 173Ga. Code 20-2-166. 174Mont. Code Ann 20-9-301 to 20-9-368. 175Mont. Code Ann. 20-0-301 to 20-9-366. 176Mont. Code Ann. 20-9-367 to 20-9-368. 177ok Sch. Code 70 18-109.2(B) (1). 178ok. Sch. Code 70 18-109.2(B) (3). 179Ky. Rev. Stat. Ann. 160.470(12) (a). 180Ky. Rev. Stat. Ann. 157.440(1) (a). 181Ky. Rev. Stat. Ann. 157.440(2). 73 182 carrollton-Farmers Branch Independent school Dist, v. Texas. 826 s.w.2d 489 (1992). 183Tex. Educ. code Ann. 16.252. 184Tex. Educ. Code Ann. 16.302 185Tex. Educ. Code Ann. 16.303. 186oavid Vaughan, "The Impact of Florida's 1973 School Finance Reform on Poor and Minority Children," in Robert Brischetto (ed.), Minorities, the Poor, and school Finance Reform (Washington: National Institute of Education, 1979). 18 7 Ibid., 15. 188Ibid., 17-25.
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74 189rbid. 25-37. 190stephen J. Carroll and Rolla E. Park, The Search for Equity in School Finance (Cambridge, MA.: The Ballinger Press, 1983). l9 1 stephen J. Carroll, The Search for Equity in School Finance; Results from Five States (Santa Monica, CA: The Rand Corporation, 1979). 192carroll and Park, 83. l93rbid, 84-85. 194rbid, 85. 195rbid, 87. 196rbid. 19 7 rbid, 88. 198rbid, 91. 199Kern Alexander and Lee Shiver, "Equalization Among Florida School Districts," Journal of Education Finance 9 (Summer, 1983), 55-62. 200rbid., 55-56. 201rbid., 56-57. 202rbid., 57-59. 203rbid., 59. 204rbid., 59-61. 2 05rbid., 62. 206steven D. Stark, Davids. Honeyman, and R. Craig wood, An Examination of the Florida Lottery (Gainesville, FL: UCEA Center for School Finance, 1991); Steven Stark, David S. Honeyman, and R. Craig Wood, "The Florida Lottery: Its Use as a Substitute for Existing Funds and its Effects on the Equity
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of School Funding," J:Qurnal Qf Educ at iQn finance 18 (Winter, 1993) 231-242. 20 7 stark, Honeyman, and Wood, An 1::xaminatiQn Qf the FlQrida LQtterv, 7 208stark, Honeyman, and Wood, An Examinat iQn Qf the FlQrida LQtterv, 13. 209stark, Honeyman, and Wood, AD 1::xaminatiQn Qf the FlQrida LQttery, 14. 210s tark, Honeyman, and Wood, AD ExaminatiQn Qf the flQrida LQtterv, 15-16. 2llstark, Honeyman, and Wood, AD ExaminatiQn Qf the FlQrida LQtterv, 16. 212s tark, Honeyman, and Wood, An Examinsat ,iQn Qf the FlQrida LQtterv, 16-17. 213J. Michael O'Loughlin, R. Craig Wood, and David S. Honeyman, A Study Qf the Effects Qf the sparsity Supplement Qn the E@itY Qf the FlQrida EducatiQn Finance PrQgram (Gainesville, FL: UCEA Center for Education Finance, 1992). 214rbid., 13-14. 2l5rbid., 12. 216rbid., 14-24. 217 Ibid., 19-24. 218rbid., 24. 2l9Gaylon D. Currie, An ExaminatiQn Qf the Equity Qf capital outlay Funding Qf Public EducatiQn: A CQwarisQn Qf the Equity Qf the current MethQd Qf Distributing capital outlay Funding in the state Qf FlQrida and the E@ity Qf General Expenditures fQr EducatiQn (Doctoral Dissertation, University of Florida, 1992). 220rbid, 98. 221rbid., 114-120. 75
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76 222rbid., 120-126. 223rbid, 127-128. 224rbid, 128-129. 225rbid, 145-146. 22 6rbid 132. 227 Ibid., 115-120. 228rbid., 120-126. 229rbid., 127-128. 230rbid., 128-129. 231rbid., 145-147 232rbid., 153.
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CHAPTER 3 METHOD The present study focused on the effects of revenues raised through local discretionary millage rates on the fiscal equity of a foundation school distribution system. In the previous chapter the relevant literature was reviewed. This chapter includes a discussion of the method by which these equity effects were examined. The chapter begins with a discussion of the population from which the data were derived Following is a description of the education funding system of Florida, the state chosen for the study. The next section provides a description of the design of the data. The chapter concludes with a discussion of the method through which the disequalizing effects of the local levies were assessed. Population The foundation distribution system of the state of Florida was chosen for this study. Several reasons were involved in the selection of Florida as the target state First, Florida's education funding system was well suited to the question being addressed. The Florida distribution system included a foundation component in which per-pupil r-evenues were equalized by the state among the districts. 77
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78 Addit i onally, local districts had the authority to raise two discre t ionary levies and the revenues generated by these levies were not equalized by the state Thus, intuitively the possibility exists that these levies introduced disequalizing effects when added to revenues generated through the foundation program. The purpose of this study was to determine the magnitude of these disequalizing effects, if they indeed existed. Second, although at the time of this writing the current foundation system of Florida has avoided a major equity court decision, 1 the foundation program of any state is susceptible to an equity lawsuit. Thus, equity effects such as those examined in the present study might be relevant in the context of any future equity court decisions. Third, the people of Florida are guaranteed by law a fiscally equitable system for financing public schools Funds for schools are to be distributed in such a manner as to ... guarantee to each student in the Florida public school system the availability of programs and services appropriate to his educational needs which are substantially equal to those available to any similar student notwithstanding geographic differences and varying local economic factors. 2 Assessing the extent to which equity aspects of these legal require m ents were being met was addressed in the present study
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79 Fourth, results from recent studies have indicated that the foundation portion of Florida's funding system is relatively equitable. 3 Therefore, a good baseline existed from which this study operated. The present study included an assessment of the degree of disequalization introduced by discretionary levies on a relatively equitable foundational system Fifth Florida is one of the nation's most populous states and has one of the nation's largest public school enrollments. Additionally, both the population in general and school enrollment in particular have been growing rapidly relative to the nation as a whole. Therefore, Florida is significant from a national perspective. 4 Following is a more detailed discussion of the population of the present study. The public school system of Florida is divided into sixty-seven local districts, each countywide. In 1990-91, the state served an unweighted full-time membership enrollment of 2,043,046.57. The district with the largest FTE was Dade at 356,960.28 and the smallest was Glades with 915.46. 5 The enrollment of Florida"s public schools has seen a pattern of overall growth since the 1970s, while nationally school enrollments have declined slightly during that time. In 1969-70, the public school enrollment nationwide was 41,934,376. This enrollment had fallen to 38,288,911 a decade later in 1979-80, and had fallen further to 37,778,512
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by 1989-90. The enrollment of Florida"s public schools, however grew steadily during this period. In 1969-70, the Florida public school enrollment was 1,312,693 Enrollment had grown to 1,464,461 in 1979-80 and 1,646,583 in 1989-90. 6 Total expenditures for Florida public schools has increased rather dramatically during this same time period. In 1969-70, total expenditures were $961,273,000. In 197980, expenditures had grown to $2,766,468,000 and to $8,228,531,000 by 1989-90. 7 Per-pupil expenditures likewise have undergone a sharp increase. Per-pupil expenditures in Florida public schools were $2,461, $3,198, and $4,497 in 1969-70, 1979-80, and 1989-90, respectively. 8 80 The average statewide per-pupil expenditure was $4,475 in 1990-91. The per-pupil expenditure among districts ranged from a high of $5,489.00 in Hamilton County to a low of $3,836 in Clay County. 9 The following section provides a description of how funds are distributed to Florida school districts. EEIT Florida"s public schools are funded primarily through the Florida Education Finance Program (FEFP), the state school funding mechanism since 1973. 10 The basic component of the FEFP is a foundation formula which is equalizing in nature. The state in addition to the foundational grants provides categorical funding and special allocations to
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81 finance more specific educational needs of the various local school districts. 11 Following is a brief introductory overview of the calculation of the FEFP formula in 1992-93, after which a more detailed discussion of the system is provided. The funds distributed to each local school district through the FEFP were calculated by multiplying the full-time equivalent (FTE) enrollment of each specific program of education by the program cost factor assigned it by the Legislature. The resultant weighted FTEs were multiplied by the base student allocation. This product was multiplied by the district cost differential, which accounted for disparate costs of living of the communities served by the various districts. To this new product supplemental allocations were added, depending on district eligibility. These included the declining enrollment supplement, sparsity supplement, and funding adjustment. When eligible supplements had been added, the result was the total state and local dollars to which the district was entitled. The required local effort, the amount the district was required to contribute in order to participate in the FEFP, was subtracted, resulting in the State FEFP contribution to that school district. To this result, adjustments were made, resulting in the net state FEFP allocation to the district. 1 2
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82 The aggregate amount of moneys to be distributed to the local school districts from the state is annually determined through legislative appropriation. 1 3 For 1992-93 a total of $4,165,594,766 was appropriated from the state treasury to be distributed to the local districts through the FEFP. Of this, $40,500,00 was appropriated from the State School Trust Fund and the remainder from the General Revenue Fund. 14 The formula was enrollment driven, and therefore each district's funding was based on weighted FTE Each district's weighted FTE was calculated through surveys taken throughout the year of student membership in the various programs. 15 The FTE for each program area was weighted according to cost factors assigned to the individual program areas The weighted FTE for the district was the product of the FTE of each program area and the program area"s cost factor. 16 In utilizing these program cost factors, differences in educational costs based on grade level differences and differences based on program of instruction were recognized. Grade level and programmatic cost factors were incorporated into the FEFP which were designed to base financial support on these differences 17 The use of cost factors resulted in a system of unequal treatment of unequals, which addressed the problem of vertical equity. A list of the cost factors assigned by the Florida Legislature for the 1992-93 fiscal year is included in appendix A.
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Weighted FTEs as determined herein were multiplied by the base student allocation (BSA) 18 The BSA was set at $2,256.98 by the Florida Legislature for the 1992-93 school year. 19 Three adjustments were made to this amount in recognition of varying fiscal conditions faced by the local districts. These included the district cost differential, the declining enrollment supplement, and the sparsity supplement. The district cost differential was intended to equalize distributions to districts based on the relative costs of living associated with the communities they serve. The cost factors used in the formula were based on the Florida Price Level Index as determined by the Office of the Governor. Specifically, the sum of the last three year's indexes were divided by three, multiplied by 0.008 and added to 0.200. 20 In the 1992 Appropriations Act, these differentials were indexed in such a way that the lowest value was 1.000. Additionally, the districts were placed in regions corresponding to the state"s judicial circuits, and all districts in a given region were given the highest value calculated for any district in the region. 21 The declining enrollment supplement was intended to alleviate the decrease in funding which accompanies a drop in enrollment. Districts with a decrease in unweighted FTE from the prior year were provided an 83
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allocation. 22 For these eligible districts, 50 percent of the decline was multiplied by the prior year FEFP per unweighted FTE and added to the current year allocation. 23 The sparsity supplement was intended to assist rural districts that faced additional cost burdens associated with population sparsity (i.e., higher per pupil transportation costs) 24 An allocation was provided to districts with an unweighted FTE of 19,000 or less. A total of $20,000,000 was distributed through the sparsity supplement for the 1992-93 school year. 25 84 The result of the addition of eligible supplements to the product of the weighted FTE and the BSA was the total gross state and local FEFP dollars available to the district. A funding adjustment was applied to ensure that the district received the same percentage change in funding as occurred in 1991-92. 26 From this result the aggregate required local effort (RLE) was subtracted. The district's RLE was based on the product of the RLE millage rate and the local assessed valuation of property. 27 Following is a discussion of the method by which the RLE millage rates for all districts were determined. The aggregate required local revenue used for general funding of schools (in addition to the state contribution through the FEFP) is determined on an annual basis by the Legislature. 2-B For the 1992-93 fiscal year, the aggregate
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85 local amount was set at $3,034,690,407. 29 Using the tax rolls provided by the Department of Revenue, the commissioner of education computed the millage rate which when applied to 95 percent of the total nonexempt property in the state would generate the proscribed aggregate required local effort. 3 0 The result was the basic millage rate for all the districts. Equalization factors were then used to determine the specific RLE millage rates for the individual districts. The factor for a given district was equal to the quotient of the prior year's state aggregate assessment level divided by the prior year's assessment of that district, subtracted from one. The resultant equalization factor was then multiplied by the basic millage rate to determine the RLE millage rate for the district. 31 School board approval of the RLE millage rate was required in order for a given district to receive FEFP funds from the state. 32 The subtraction of the required local effort from the gross state and local FEFP dollars resulted in the state FEFP dollars. To this amount funding adjustments were made, which accounted for arithmetical errors, tax roll changes, FTE errors or other allocation errors. The result of these adjustments was the net state FEFP dollars. 33 The combination of the net state FEFP funds and the required local effort represented the foundation element of the FEFP. In addition to foundation funding, categorical program funds and special allocations were made to the districts.
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86 Because these categorical programs and special allocations were not part of the analysis of the present study, these special funding programs for 1992-93 are listed briefly without being discussed in detail. Categorical programs included Comprehensive School Construction and Debt Service, 34 Community Schools, 35 School Lunch, 36 Instructional Materials, 37 and Student Transportation. 38 Special Allocations were Blue Print for Career Preparation, Pre-School Projects, Safe Schools, Summer Inservice Institutes, Programs of Emphasis, Full Service Schools/Interagency Cooperation, and Education Business Cooperative. 39 The local revenue used to support public schools in Florida for any given year is derived from property taxation. 40 Local school districts are authorized to tax property for support of education by the Florida Constitution. 41 Five categories of millages are used for support of public schools. The first is the required local effort school operating millage, as established in the FEFP. 42 The second is the discretionary millage, determined by each local school board (within the statutory limitations) without a vote of the electorate. 43 The third is the capital outlay and maintenance millage, determined by each school board without a vote of the electorate. 44 The remaining two millage ca t egories require both local school board and voter approval. The fourth category is a special school operating millage 45 and the fifth is a debt service millage. 46 Local
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87 districts are prohibited by the Florida Constitution from exceeding 10 mills from the combination of the required local effort, discretionary, and capital outlay and maintenance rates in a given year 47 The present study focused on the disequalizing effects of the two nonvoted millage rates, discretionary millage and the school capital improvement millage, when combined with revenues obtained through the equalized foundation portion of the FEFP. Thus, the focus was on the disequalizing effects of the two rates which each were applied at local board discretion The discretionary millage rate, the levies from which were not equalized by the state, was determined by each individual school board without a vote by the local electorate. Districts were permitted to use revenues qbtained from the application of the discretionary millage rate to support current operations. The Legislature annually prescribes the maximum discretionary millage rate that the districts may choose, never to exceed 1.6 mills. 48 The 199293 maximum discretionary millage rate was set at 0.510 mills by the Florida Legislature. 49 The capital outlay and maintenance millage rate for a given district was determined by the local school board without the approval of the electorate. There are statutory requirements and restrictions concerning the levies resulting from the application of the capital outlay and maintenance
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88 rates. These revenues could be used for district new construction and modeling projects, sites and site improvement or expansion to new sites, existing auxiliary facilities or ancillary facilities, 50 or to fund maintenance, renovation, and repair of existing school plants. 51 These revenues could furthermore be used to support pupil transportation by their use in purchasing school buses, driver education vehicles, plaint maintenance related vehicles, security vehicles, or vehicles related to storing or distributing materials and equipment. 52 New or replacement equipment could also be purchased using these funds. 5 3 Districts were permitted to use the revenues obtained through the capital outlay and maintenance rate for payments for educational facilities and sites due under a lease purchase agreement, as long as these funds do not exceed one half of the total levy from the millage rate. 54 The revenues could be used for the payment of certain loans used to finance school facilities. 55 These loans were restricted to a term of one year or less, unless otherwise extended by the lender but never to exceed four years. Additionally, the amount of the loan could not exceed one-fourth of the total ad volarem revenue from the preceding fiscal year. 56 Districts could also use these revenues to pay costs related to complying with state and federal environmental requirements and regulations governing school facilities. 57
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Finally these revenues could be used to support payment of the costs of leasing relocatable educational facilities. 58 89 Of the three nonvoted, locally derived millage rates used for support of schools, only the required local effort portion was supplemented by matching state funds in order to equalize the distribution among districts. The discretionary levies and the levies resulting from the capital improvement millages were not equalized on a statewide basis. The disequalizing effects of these levies when combined with foundation program revenues is the focus of this study. The following section includes a discussion of the specific method by which these equity effects were examined. Design This study addressed the question, "To what extent did local discretionary levies introduce disequalizing effects into an equalized foundation program?" The previous section included a summary of the FEFP as it operated in 1992 93 f i scal year The current section includes a discussion of the des i gn of the study. Fiscal equity in the realm of education finance refers to fairness in the distribution of fiscal resources. Any examination of the fiscal equity of a distribution system requires measurement of fiscal resources in order to determine the degree to which the distribution is equitable. Generally, either per-pupil expenditures or per pupil
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90 revenues are used to represent resource availability in equity studies. In the current study, per-pupil revenues were chosen as the measurement object. The rationale for choosing per-pupil revenues as opposed to per-pupil expenditures was the fact that revenues could be matched with their millage rate source, whereas expenditures were not ~dentified by such a source. Thus, in the present study per pupil revenues was representative of resources used to support education. To determine the degree of disequity caused by introduction of revenues raised through application of the discretionary millages and capital outlay and maintenance millages, per-pupil revenues were examined across seven levels of aggregation. The first level included the per pupil revenues distributed through the foundation portion of the FEFP. An examination of this aggregate level provided a baseline from which the degree of disequalization caused by the two local discretionary levies was assessed. The second and third levels of aggregation included the distribution among the local districts of per-pupil revenues raised through application of the discretionary and the capital outlay and maintenance millage rates, respectively. An analysis of per-pupil revenues distribution in these two levels of aggregation demonstrated the relative degree of fiscal inequity, if any, of each of the locally determined millage rate levies. The fourth level of aggregation
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91 included the combination of the discretionary and the capital outlay and maintenance levies, and the results from this level indicated the total degree of disequalization resulting from the two levies. The fifth, sixth, and seventh levels of aggregation included combinations of the first through fourth. The fifth aggregation level included the per-pupil revenues distributed through the foundation portion of the FEFP combined with the per-pupil revenues raised through application of the discretionary millage rate. The sixth level of aggregation included a combination of per-pupil revenues distributed through the foundation portion of the FEFP combined with the per-pupil revenues raised through application of the capital outlay and maintenance millage rate. The results from these two levels, when compared to the results from aggregate level one, indicated the magnitude of the inequity introduced through application of each of the two unequalized millage rates, respectively. The seventh and final level of aggregation included the combination of the per-pupil revenues distributed through the foundation program, the per-pupil revenues generated through application of the discretionary millage rate, and the per pupil revenues generated through application of the capital outlay and maintenance millage rate. The results from this final level of aggregation, when compared to the results from aggregate level one which included the foundation portion
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only demonstrated the total disequalizing effects of the revenues generated through the two millage rates. 92 Per-pupil revenues across these seven levels of aggregation were examined in light of three standards of fiscal equity These included resource accessibility, wealth neutrality, and tax yield. Following is a discussion of each of these concepts, coupled with the specific quantitative techniques through which they were assessed. Measurement The previous section included a description of the design of the data for this study. In this section the method by which fiscal equity was measured is presented. In most equity studies resource accessibility, wealth neutrality, and tax yield have been the means of assessing ~he relative equity of a distribution. 59 In the present study measures related to all three of these equity constructs were used to assess the degree of disequalization introduced by the two millage rates. In the present study, the revenues generated through the application of the discretionary and capital outlay and maintenance millage rates were examined to determine the effects on student resource accessibility. Resource accessibility is a per-pupil equity construct which refers to the degree to which all students have access to a roughly equivalent resource base of fiscal support for education.
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93 The more equivalent accessibility to resources among students, the greater the degree of fiscal equity in the system for distributing these resources. The mean, range, restricted range, federal range ratio, variance, standard deviation, and coefficient of variation are typically used to measure resource accessibility. 60 The mean is a measure of the central tendency of a distribution. The mean is calculated using the following formula: [L(Pi Xi) / LPi] / N where Pi refers to the number of pupils in district i, Xi is the per-pupil revenue in district i and N is the number of districts in the state. 61 In the present study a mean amount of per-pupil revenues was calculated at each level of aggregation. Comparisons of district wide mean per-pupil revenues with the statewide mean provided a precursory assessment of the differences in resource accessibility among the districts. The range refers to the difference between the highest value and the lowest value in a given distribution. In the present study, the range represents the difference between the maximum and the minimum per-pupil revenues among all the districts. The following formula is used to calculate the range:
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94 Highest Xi Lowest Xi where Xi is the per-pupil revenue in district i. 62 In the present study a separate range was calculated at each level of aggregation. Larger ranges are evidence of less equivalent resource accessibility, whereas smaller ranges indicate greater resource accessibility equivalence. In the present study, the particular concern was the amount of growth of the range with the inclusion of the discretionary and capital outlay and maintenance levies into revenues distributed through the foundation program The restricted range is the difference between the per pupil revenues of the district at the 95th percentile and the revenues per pupil of the district at the 5th percentile. The restricted range has an advantage over the range by virtue of the fact that the extremes of the distribution are not included in the calculation of the restricted range. Therefore, the restricted range is less influenced by outliers than the range. 63 The following formula is used to calculate the restricted range: Xi at 95 percentile Xi at 5 percentile
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where Xi is the per-pupil revenue generated in district i. 64 In the present study a restricted range was calculated for per-pupil revenues at each of the seven levels of aggregation. 95 Larger restricted ranges are an evidence of less equivalent resource accessibility, whereas smaller ranges are an indication of greater resource accessibility equivalence. In the present study, the particular concern was the amount of growth of the restricted range with the inclusion of the discretionary and capital outlay and maintenance levies into the revenues generated through the foundation program. The federal range ratio refers to the ratio of the restricted range to the per-pupil revenues of the district at the 5th percentile. The following formula is used to calculate the federal range ratio: (Xi at 95 percentile Xi at 5 percentile) / Xi at 5 percentile where Xi is the per-pupil revenue generated in district Xi. 65 In the present study a federal range ratio was calculated for per-pupil revenues at each of the seven levels of aggregation included in the present study. The federal range ratio is typically restricted to values ranging from Oto 1. The lower a federal range ratio, the more equivalent the accessibility to resources, with 0
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indicating perfect equity. Increasing federal range ratios indicate increasing inequity in the distribution of funds. 96 In the present study, the particular concern was the amount of growth of the federal range ratio with the inclusion of the discretionary and capital outlay and maintenance levies into the revenues distributed through the foundation program. The variance refers to the average of the squared deviations from the mean. Increasing variance is associated with increased variation in the distribution. The variance is calculated using the following formula: L[Pi (Xp Xi) 2 ] / LPi where Pi refers to the number of pupils in district i, Xp is the mean revenues per pupil for all pupils in the state, and Xi is per-pupil revenues in district i. 66 In the present study the variance in the distribution of per-pupil revenues was calculated at each level of aggregation. Increasing variance is an indication of less equivalent resource accessibility, whereas decreasing variance is an indication of greater resource accessibility equivalence. In the present study, the particular concern was the amount of growth of the variance with the inclusion of the discretionary and capital outlay and maintenance levies into the revenues distributed through the foundation program.
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The standard deviation is the square root of the variance. The following formula is used to calculate the standard deviation: {I[Pi (Xp Xi) 2 ] / IPi} 97 where Pi refers to the number of pupils in district i, Xp is the mean revenues per pupil for all pupils in the state, and Xi is per-pupil revenues in district i. 67 A standard deviation was calculated for the revenues per-pupil at each of the seven levels of aggregation in the present study. Larger standard deviations are associated with less equivalent resource accessibility across a distribution, and therefore greater inequity. Smaller standard deviations are associated with greater resource accessibility equivalence, and therefore greater equity. In the present study, the particular concern was the amount of increase in the standard deviation with the inclusion of the discretionary and capital outlay and maintenance levies into the revenues distributed through the foundation program. A coefficient of variation is the ratio of the square root of the variance of the distribution to the mean of the distribution. Thus, whereas the variance and the standard deviation are expressed in terms of the units in the distribution, the coefficient of variance provides a standardized ratio, which normally falls between O and 1.
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98 The following formula is used to calculate the coefficient of variation: {I[Pi {Xp Xi) 2 ) / IPi} / Xp where Pi refers to the number of pupils in district i, Xp is the mean per-pupil revenues for all pupils in the state, Xi is per-pupil revenues in district i, and Xp is the mean per ~upil revenues for all districts. 68 In the present study the coefficient of variation was calculated for per-pupil revenues at each level of aggregation. The coefficient of variation normally falls between 0 and 1. The lower a coefficient of variation, the more equivalent the accessibility to resources, with O indicating perfect equity. An increasing coefficient of variation indicates increasing inequity. In the present study, the particular concern was the amount of growth of the coefficient of variation with the inclusion of the discretionary and capital outlay and maintenance levies into the revenues distributed through the foundation program. Through the application of the preceding quantitative measures the degree of resource accessibility, the equivalence of levels of support for education on a per-pupil basis, was assessed. The level of support for the present study was expressed as per-pupil revenues. An equitable system of funding schools is one in which all students have
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99 roughly equivalent access to resources for education. Resource accessibility, however, is not the sole determinant of the degree of fiscal equity in an education funding system. Equity may also be assessed through measuring the degree of wealth neutrality and equivalent tax yield. Following is a discussion of the measurement of wealth neutrality specifically related to the question addressed in the present study. Wealth neutrality, also referred to as fiscal neutrality, is a theoretical concept implying lack of relationship between local fiscal conditions and fiscal support for education. A wealth neutral system of distribution i s one in which a student's level of financial support for education is not a function of the relative wealth of the district in which he or she is educated. 69 The degree of wealth neutrality is generally measured through regression techniques, through which the relationship between local fiscal conditions and education resources is quantified. 70 The regression measurements typically include the correlation coefficient, coefficient of determination, and regression coefficient In addition, two econometric measures the Gini coefficient and the McLoone index provide a measure of wealth neutrality. 71 A discussion of these measures and their use in the current study, beginning with chose related to regression, follows
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100 Correlation refers to the strength, or degree, of the relationship between two variables. The correlation coefficient provides a measure of the strength of association. 72 A correlation coefficient is restricted to values ranging from 1.0 to 1.0. A positive correlation coefficient indicates a direct relationship between the two variables, with increasing values of the first variable being associated with increasing values of the second variable. A correlation coefficient of 1.0 indicates a perfect positive relationship between the two variables. Conversely, a negative correlation coefficient indicates an inverse relationship between two variables. In this case, an increase in the value of the first variable is associated with a decrease in the value of the second variable. A correlation coefficient of -1.0 indicates a perfect inverse relationship between the two variables. A correlation coefficient of 0 indicates that no relationship between the two variables exists. In assessments of wealth neutrality, a measure of local district wealth is correlated with support for education on a per-pupil basis. In the present study, per-pupil revenues were chosen as the variable representing support for education and district assessed valuation was chosen as the variable representing local wealth. Assessed valuation was the logical choice given the fact that local revenues for
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school support are raised through property taxation in Florida. 101 Ideally, a correlation coefficient of zero indicates perfect wealth neutrality, an indication that students' level of education support is not dependent on local wealth. An increasing correlation coefficient is associated with decreasing wealth neutrality and therefore greater inequity. 73 A negative correlation coefficient provides evidence that as local assessed valuation increases, there is a corresponding decrease in revenues per-pupil generated. Technically, this is not an indication of inequity. 74 The specific formula used to calculate the correlation coefficients for wealth neutrality assessments is as follows: l[pi (Xi Xp) l{pi (xi xp)2 1 (Wi Wp)] / (Wi Wp) 2 ]} where Pi is the number of pupils in district i, Xi is the revenues per-pupil in district i, Xp is the mean per-pupil revenues for all districts, Wi is the assessed valuation per pupil in district i, and Wp is the mean assessed valuation per-pupil for all districts. 75 In the present study the correlation coefficient was calculated at each level of aggregation. Of particular interest in assessing the effects on the wealth neutrality of the FEFP distribution system was any increase of the
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102 correlation between local assessed valuation and per-pupil revenues with the inclusion of revenues raised through application of the discretionary and capital outlay and maintenance millage rates into revenues provided through the foundation system. Such an increase, if any, was indicative of the degree of disequalization resulting from these levies. The second measure used in assessing the degree of wealth neutrality is the coefficient of determination. Whereas the correlation coefficient is a measure of the strength of association between two variables, the coefficient of determination represents the percent of variation in a dependent variable that is explained by a predictor variable. The coefficient of determination for a two variable model is calculated by squaring the correlation coefficient. Thus, a coefficient of determination is restricted to values between O and 1, with O indicating none of the variance in the outcome variable explained by the predictor variable and 1 indicating 100 percent of the variance explained by the predictor variable. Of course, the coefficient of determination, unlike the correlation coefficient, does not indicate whether the relationship between the two variables is positive or negative. 76 A coefficient of determination of O is an indication of perfect wealth neutrality, and therefore distributional equity Such a coefficient indicates that none of the variations among districts in per-pupil revenues can be
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accounted for by variations in local wealth. Increasing coefficients of variation indicate increasing variance explained by local wealth, and therefore is evidence of decreased wealth neutrality and greater inequity. 103 In the present study, the percent of variation in local assessed valuation was used as the predictor of per-pupil revenues. A coefficient of determination was calculated for per-pupil revenues at each level of aggregation. Of particular interest was any increase in the proportion of variance in per-pupil revenues explained by local wealth when revenues generated through application of the discretionary millage rates and capital outlay and millage rates were added to per-pupil revenues distributed through the foundation system. The third quantitative tool used to assess wealth neutrality is the regression coefficient, also known as the slope of the regression equation. The regression coefficient is based on regression analysis, a process through which an outcome, or dependent, variable is mathematically expressed ~s a function of one or more predictor, or independent, variables. 77 This relationship is expressed by the following equation:
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104 where Yi is the is the outcome variable for i, Bo is the intercept term, gl is the regression coefficient or slope of the predicted line, Xi is the value of the predictor variable at i, and Ui is the error at i. 78 Thus, while a correlation coefficient indicates the strength of the relationship between two variables, the regression coefficient provides a measure of the magnitude of the change in one variable associated with the change in the other variable. A regression coefficient, unlike the correlation coefficient and coefficient of determination, is not expressed in standardized units. The regression coefficient is expressed in terms of the units of measurement of the outcome variable, and may be computed using the following formula: L[Pi (Xi Xp) (Wi Wp)] / L[Pi (Wi Wp) 2 ] where Pi is the number of pupils in district i, Xi is the revenues per-pupil in district i, Xp is the mean per-pupil revenues for all districts, Wi is the assessed valuation per pupil in distr i ct i, and Wp is the mean assessed valuation per-pupil for all districts 79 A regression coefficient in the present study was expressed as the dollar amount of change in per-pupil revenues resulting in a one dollar change in assessed valuation per-pupil A regression coefficient was calculated at each level of aggregation.
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In the present study, the change in the regression coefficient when per-pupil revenues raised through application of the discretionary and capital outlay and maintenance millage rates were added to the per-pupil revenues distributed through the foundation system was of particular interest. Any resultant increase in this relationship indicated decreasing wealth neutrality and decreased fiscal equity 105 These three regression measures were used to assess the relationship between wealth and revenues. Two econometric measures, the Gini coefficient and McLoone index, were also used to assess the effects of wealth neutrality caused by the two levies. In measures of wealth neutrality the Gini Coefficient demonstrates how far the distribution of revenues is from providing each percentage of pupils with an equal percentage of the revenues. B o The following formula is used to calculate the Gini coefficient: Li lj [Pi Pj (Xi Xj)] / 2 (1Pi)2 Xp where li is the sum for district i, lj is the sum for district j, Pi is the number of pupils in district i, Pj is the number of pupils in district j, Xi is the revenues per pupil in district i, Xj is the revenues per pupil in district j, and Xp is the mean revenues per pupil for all districts B l Gini coefficients are limited to values ranging from Oto 1.
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106 A Gini coefficient of O indicates perfect wealth neutrality and therefore equity in the distribution, while a Gini coefficient of 1 indicates complete systematic inequity. In the present study the Gini coefficient was calculated for revenues at each level of aggregation. The amount of increase, if any, of the Gini coefficient from the foundation level of aggregation to each aggregate level including the combination of the revenues distributed through the foundation system plus the two locally determined millage rates provided indication of the magnitude of the inequity introduced by the resultant levies. The McLoone index indicates the ratio of the actual sum of per-pupil revenues for pupils below the median to the sum of per-pupil revenues that would exist if each pupil below the median were at the median per-pupil revenue level. 82 Thus, the McLoone Index conceptually is relevant to a foundational distribution, wherein a certain minimally acceptable level would be available for all students. In this case, this minimally acceptable level would be the statewide median per-pupil revenues. The following formula is used to calculate the McLoone Index: L ( 1... j ) (Pi Xi) / Mp l:(1.. j) (Pi)
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107 where districts 1 through j are below the median, Pi is the number of pupils in district i, Xi is the per-pupil revenues in district i, and Mp is the statewide median revenues per pupil for all districts. The McLoone Index is restricted to values between O and 1. A value of O indicates complete lack of wealth neutrality and therefore inequality below the median. Values approaching 1 indicate that pupils in districts below the median have been provided more equitable distribution of revenues. In the present study McLoone indexes were calculated for per-pupil revenues at each level of aggregation. Of particular interest was the change in the McLoone Index when the per-pupil revenues from the application of the discretionary and capital outlay and maintenance millage rates were added to the revenues distributed through the foundation system. Such a change, if any, was indication of the impact of these two levies on fiscal equity for those districts below the median in terms of per-pupil revenues. The preceding measures assessed the degree to which the two levies affect the wealth neutrality of the foundation system. Wealth neutrality and resource accessibility provided two sets of standards through which the degree of equity of a distribution system is assessed. A third area of equity assessment was tax yield.
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108 In studies of education finance systems tax yield refers to the relationship between the degree of local fiscal effort directed toward supporting education and the resulting resources. Tax yield therefore is associated with taxpayer equity, in which equal effort should result in equal yield. Through tax yield equity assessment the relationship between the tax effort exerted in the local districts and the per pupil revenues generated through the tax is measured. The degree of equivalence of tax yield is demonstrated by the extent to which the degree of effort exerted by the taxpayers in a district is related to the per-pupil revenues generated through application of these tax rates. The relationship may be measured through regression techniques. The correlation coefficient provides a measure of the strength of association between the tax rate and the resultant per-pupil revenues generated through application of these tax rates. The higher a positive correlation coefficient, the more the equivalent yield given equivalent effort. A correlation coefficient of 1.0 indicates perfect ~quity. A correlation coefficient of zero indicates no relationship between effort and yield, which is an inequitable situation in that yield should be positively related. Negative correlation coefficients indicate even greater inequity, meaning that with increased tax effort there is an associated decrease in per-pupil revenues. A
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109 correlation coefficient of -1 implies the greatest degree of taxpayer inequity. The correlation coefficient is calculated as follows: l[Pi (Xi Xp) l{Pi (Xi Xp)2] (Ti Tp)] / (Ti Tp) 2 ]} where Pi is the number of pupils in district i, Xi is the per-pupil revenues in district i, Xp is the mean per-pupil revenues for all districts, Ti is the per-pupil millage rate for district i, and Tp is the mean per-pupil tax rate for all districts. In the present study the correlation coefficient was calculated at each level of aggregation. Of particular interest was any decrease in the correlation coefficient resulting from the addition of revenues generated through application of the discretionary and capital outlay and maintenance millage rates to the revenues distributed through the foundation portion of the FEFP. The second measure of tax yield is the regression coefficient. Typically the rate of local property taxation is regressed on per-pupil revenues resulting from these rates. The regression coefficient thus provides an indication of the magnitude of the relationship, if any, between tax effort and per-pupil revenues. A regression coefficient is calculated using the following formula:
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110 L[Pi (Xi Xp) (Ti Tp)] / L[Pi (Ti Tp)21 where Pi is number of pupils in district i, Xi is per-pupil revenues in district i, Xp is the statewide mean per-pupil revenues, Ti is the per-pupil tax rate for district i, and Tp is the statewide mean per-pupil tax rate. These regression coefficients express the dollar change in per-pupil revenues given a one mill change in the tax rate. In the present study, the change in the regression coefficient when per-pupil revenues raised through application of the discretionary and capital outlay and maintenance millage rates were added to the per-pupil revenues distributed through the foundation system was of particular interest. The amount of decrease, if any, in the regression coefficient indicated the decrease in the magnitude of the change in revenues per-pupil associated with a one mill increase in tax effort beyond the required local effort. Decreases in this relationship indicated shrinking tax yield equivalence and decreased fiscal equity. The two preceding regression measures were used to assess the equivalence of tax yield, particularly with regard to the addition of two unequalized levies. Together with the measures of resource accessibility and wealth neutrality, the degree of disequalization of the two local levies was assessed.
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conclusion The present study examined the effects of revenues raised through local discretionary millage rates on the equity of a foundation school distribution system. The chapter inciuded a discussion of the method by which these equity effects were examined. 111 Chapter 3 began with a discussion of the population from which the data used in the study were derived. Following this discussion of the population was a description of the ~ducation funding system of Florida, the state chosen for the study. The next section provided a description of the design of the present study. Chapter 3 concluded with a discussion of the method through which the disequalizing effects of the local levies were assessed. Chapter 4 includes a discussion of the results of the study. Notes 1 christensen v, Graham, Dist. court of App., case No. 88-69, has at the time of this writing not been decided; In Florida Department of Education v, Glasser. 622 so.2d 944 (Fla. 1993), a related case recently decided, the Supreme Court of Florida ruled that the Legislature could limit local school millage below the total constitutionally maximized 10 mills. 2Fla Stat. 236.012. 3J. Michael O'Loughlin, R. Craig Wood, and Davids. Honeyman, A study of the Effects of the Sparsity supplement on the Equity of the Florida Education Finance Program (Gainesville, FL: UCEA Center for Education Finance, 1992); Steven D. Stark, David S. Honeyman, and R. Craig Wood, bn Examination of the Florida Lottery (Gainesville, FL: UCEA
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112 Center for School Finance, 1991); Gaylon D. Currie An Examination of the Equity of capital outlay Funding of Public Education: A comparison of the Equity of the current Method of Distributing capital outlay Funding in the state of Florida and the Equity of General Expenditures for Education. (Doctoral Dissertation University of Florida, 1992); Steven Stark, David S. Honeyman, and R. Craig Wood, "The Florida Lottery: Its Use as a Substitute for Existing Funds and its Effects on the Equity of School Funding," Journal of Education Finance 18 (Winter, 1993). 4 see generally R Craig Wood and David S. Honeyman, "Rapid Growth and Unfulfilled Expectations: Problems for School Finance in Florida, in James Gordon Ward and Patricia Anthony (eds.) Who Pays for Student Diversity? (Newbury Park, CA: Corwin Press, Inc., 1992) 5Division of Public schools, Profiles of Florida School Districts 1992 93 Student & staff Data (Tallahassee, FL: Florida Department of Education, 1992), 8 6National Center for Educational Statistics Digest of Education Statistics (Washington, DC: U.S. Department of Education, 1992) 59. 7Ibid ., 155 8Ibid., 161. 9 1992-93 school Profiles, 4 l0Fla. Stat. 23 6. 014 ( 1) (b) llDivision of Public Schools, 1992-93 Florida Education Finance Program (Tallahassee, FL: Florida Department of Education 1992) 1 12Fla Stat. 236. 13Fla. Stat. 236.081(1). 1 4 1992-93 FEFP, 1 15Fla. Stat. 236.081(1) (a). 16Fla. stat 236 081(1) (c).
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17 1992-93 FEFP, 12. 18Fla. Stat. 236.081. 19Laws of Florida 92-293 item 516. 20Fla. Stat. 236.081(2). 21Laws of Florida 92-293 item 516. 22Fla. Stat. 236.081(7). 23 1992-93 FEFP, 15. 24Fla. Stat. 236.081(6). 25Laws of Florida 92-293 item 516. 26 1992-93 FEFP, 16. 27Fla. Stat. 236.081(4). 28Fla. Stat. 236.081(4). 29Laws of Florida 92-293 item 516. 30Fla. Stat. 236.081(4) (a) (1). 31Fla. Stat. 236.081(4) (b). 32Fla. Stat. 236.02(7). 33 1992-93 FEFP, 19. 34Fla. Stat. 236.081(5) (a) (1). 35Fla. Stat. 236.081(5) (a) (2). 36Fla. Stat. 236.081(5) (a) (3). 37Fla. Stat. 236.081(5) (a) (4). 38Fla. Stat. 236.081(5) (a) (5). 39 1992-93 FEFP, 21. 113
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114 40Ibid., 2. 41Fla. Const. art. VII sec. 9 (a) 42Fla. Stat. 200.001(3) (a). 43Fla. Stat. 200. 001 ( 3) (bl 44Fla. Stat. 200.001(3) (d). 45Fla. Stat. 200.001(3) (c). 46Fla. Stat. 200.001(3) (e). 47Fla. Const. art. VII sec. 9 (a) 48Fla. Stat. 236 25(1). 49Laws of Florida 92-293 item 516. 50Fla. Stat. 236.25 (2) (a). 51Fla. Stat. 236.25(2) (b). 52Fla. Stat. 236.25(2) (cl. 53Fla. Stat. 236.25(2) (d). 54Fla. Stat. 236.25(2) (e). 55Fla. Stat. 236.25(2) (f). 56Fla. Stat. 237 .161. 57Fla. Stat. 236.25(2) (g). 58Fla. Stat. 236.25(2) (h). 59R. Craig Wood and David c. Thompson, Education Finance Law; constitutional challenges to state Aid Plans; An Analysis of Strategies (Topeka, KS: National Organization of Llegal Problems in Education, 1993), 47; David C. Thompson, R. Craig wood, and Davids Honeyman, Fiscal Leadership for Schools: concepts and Practices (White Plains, NY: Longman Publishing Group 1994), 252.
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115 60wood and Thompson,47-48; Thompson, Wood, and Honeyman, 253. 6 1 wood and Thompson, 48; Thompson, wood, and Honeyman, 254. 62wood and Thompson, 48; Thompson, Wood, and Honeyman, 254-255. 63T.W. Anderson and Stanley L. Sclove, The Statistical Analysis of Data. 2nd ed. (Palo Alto, CA: The Scientific Press, 1986), 109. 64wood and Thompson, 49; Thompson, wood, and Honeyman, 255. 65wood and Thompson, 49; Thompson, Wood, and Honeyman, 255. 66wood and Thompson, 49; Thompson, Wood, and Honeyman, 256 67wood and Thompson, 49-50; Thompson, Wood, and Honeyman, 256. 257. 68wood and Thompson, 50; Thompson, Wood, and Honeyman, 69Thompson, wood, and Honeyman, 252. 70rbid., 257. 71 rbid. 72Alan Agresti and Barbara Finlay Agresti, Statistical Methods for the social Sciences (San Francisco: Dellen Publishing Co., 1979), 233. 73wood and Thompson, 51. 74Robert Berne and Leanna Stiefel, The Measurement of Equity in School Finance (Baltimore: The Johns Hopkins University Press, 1984), 28. 75wood and Thompson, 51; Thompson, Wood, and Honeyman, 259-260. 76Agresti and Agresti, 234-242.
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77rbid., 15-18. 7 8samprit Chaterjee and Bertram Price, Regression Analysis by Example, 2nd ed. (New York: John Wiley & sons, inc., 1991), 3. 79Berne and Steifel, 29. 80rbid. 81Thompson, Wood, and Honeyman, 258 8 2 rbid. 116
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CHAPTER 4 RESULTS The present study addressed the following research question: In a state with a foundation program for support of schools including one or more discretionary millage rates, to what extent do the levies resulting from the application of the discretionary millage rates introduce inequities into the system for distributing education funding? Chapter 3 included a discussion of the particular data design and procedures used in the study to examine these disequalizing effects. The present chapter includes a description of the results of the analysis. The current chapter begins with a review of the methodology presented in Chapter 3. Following this review is a discussion of the results related to the measures of resource accessibility. The chapter concludes with a presentation of the results of the wealth neutrality and the tax yield measures. Data for the present study were taken from the final calculation of the Florida Education Finance Program (FEFP) from fiscal year 1992-93, 1 the most recent year for which the final calculation data were available. The study included examination of the equity of the distribution of education 117
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118 dollars among the sixty-seven Florida school districts during that fiscal year. Each of the fiscal equity measures was calculated across seven aggregation levels, the intent of which was to provide assessment of cumulative disequalizing effects. The first aggregate level included revenues distributed through the foundation portion of the FEFP. The second and third levels included revenues generated through the two unequalized millage rates, discretionary rate and the capital outlay and maintenance rate, respectively. The fourth level included the combination of the two unequalized rates. Levels five and six included a combination of the foundation revenues with the discretionary and capital outlay and maintenance revenues, respectively. The final level of aggregation included revenues from all three sources. The object of measurement included per-pupil revenues. Measurements related to three constructs of fiscal equity were used in the study. These constructs included resource accessibility, wealth neutrality, and tax yield. Following are the specific results of these measurements, beginning with those related to the resource accessibility of the distributions. Resource Accessibility Resource accessibility is a per-pupil equity construct which refers to the degree to which all students have access
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119 to a roughly equivalent resource base of fiscal support for education. The results of the resource accessibility measures for the current study are presented in Table 1. Table 1 Resource Accessibility: Measures of Variability Mean Found 2683 39 Disc 90.22 Cap 309.70 D + C 399.92 F + D 2773.61 F + C 2993 09 F + D + C 3083.31 Variance 4748.22 2421. 05 23365.73 37996.21 9199.42 33879.56 50501.18 Standard Deviation 69.19 49.20 152.86 194.93 95.91 184 06 224.72 Coeff of Variation .03 .55 .49 .49 .03 .06 07 The mean statewide per-pupil revenues provided through the foundation element of the FEFP was $2683.39. The mean per-pupil revenue generated by the discretionary ahd capital outlay and maintenance rates were $90.22 and $309.70, respectively, with the mean for the combination of the two unequalized rates measured at $399.92. The mean of the foundation revenues combined with the discretionary revenues was $2773.61 and combined with the capital outlay and
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maintenance revenues was $2993.09. The mean per-pupil revenues statewide from all three sources was $3083.31. 120 Increased variability of the distribution of revenues was evident as unequalized levies were added to the foundation revenues, based on the variance and standard deviation calculations. The variance of the revenues provided through the foundation program was 4748.22, with the standard deviation calculated at $69.19. The variance and standard deviation for the discretionary revenues were 2421.05 and $49.20. The variance and standard deviation for the capital outlay and maintenance revenues, 23365.73 and $152.86, far exceeded that of the foundation revenues though fewer aggregate dollars were involved. The revenues resulting from the combination of the discretionary and capital outlay and maintenance rates had a variance of 37996.21 and a standard deviation of $194.43. The addition of the unequalized discretionary revenues had the effect of increasing the variability of the distribution of the revenues generated through the foundation program of the FEFP. The variance and standard deviation of the foundation revenues combined with the discretionary revenues were 9199.42 and $95.91. The variance and standard deviation of the foundation revenues combined with revenues generated from the capital outlay and maintenance millage rate were 33879.56 and $184.06. The revenues generated from
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all three sources had a variance of 50501.18 and standard deviation of $224.72. 121 Clearly the estimates of distributional variability increased with the inclusion of the unequalized revenues. However, these measures were based on separate distributions, each with varying amounts of aggregate dollars involved. Therefore, examination of the coefficients of variation, providing standardized estimates of variability, was instructive. The coefficients of variation for the uncombined revenue sources were for the foundation revenues .03, for the discretionary revenues .55, and for the capital outlay and maintenance revenues .49. The coefficient of variation for the combination of the discretionary and capital outlay and maintenance revenues was calculated at .49. The inclusion of the unequalized revenues demonstrated an increase in the variability of foundation dollars, as measured by the coefficient of variation, only with the inclusion of the capital outlay and maintenance revenues. The coefficient of variation increased from .03 to .06 with the inclusion of these revenues in the calculation. However, the coefficient of variation remained at .03 when the discretionary revenues were combined with the foundation ~evenues. The coefficient of variation calculation for revenues from a combination of all three sources was .07.
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122 The preceding measures demonstrated the degree of revenue variability among Florida school districts across the seven aggregation levels. Further evidence of the effects of discretionary revenues on the fiscal equity of a foundation distribution system was obtained through examination of the range related measures of the distribution. Table 2 includes the results of the range, restricted range, and federal range ratio calculations across the seven distributional levels. Table 2 Resource Accessibility: Measures of Distributional Range Range Found 424.78 Disc 332.10 Cap 772.04 D + C 997.42 F + D 648.87 F + C 880.02 F + D + C 1105.40 Restricted Range 248.23 189.96 601.88 730.05 333.36 639.65 804.24 Federal Range ratio .10 11.93 28.84 .13 .24 .29 The range for the foundation revenues alone was $424.78, while the restricted range was $248.23 The discretionary revenues range of $332.10 and restricted range of $189.96 were nearly as large as that of the foundation revenues. The
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123 capital outlay and maintenance revenues range of $772.04 and restricted range of $601.88 far exceeded that of the foundation revenues. The range for the combination of the discretionary revenues combined with those arising from the capital outlay and maintenance millage rates was $997.42, while the restricted range was $730.05. The impact on the ranges of the distribution as discretionary and capital outlay and maintenance dollars were added to foundation dollars was evident. The range of the foundation revenues combined with the discretionary revenues was $648.87, while the restricted range was $333.36. The revenues from the foundation program combined with those raised through application of the capital outlay and maintenance millage rates had a range of $880.02 and a restricted range of $639.65. The range resulting from revenues generated from a combination of all three sources was $1105.40, while the restricted range was $804.24. The federal range ratio for the foundation revenues was .10 and for the discretionary revenues was 11.93. No federal range ratio could be calculated for the capital outlay and maintenance revenues because the district at the fifth percentile (which constitutes the denominator of the federal range ratio formula) applied no millage rate and therefore raised no dollars through this source. The federal range ratio for the capital outlay and maintenance revenues
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combined with those generated through the discretionary millage rate was 28.84. 124 The addition of unequalized dollars had the effect of ~ncreasing distributional range as evident in the increase of the federal range ratios as these revenues were added to those raised through the foundation program. The federal range ratio for the foundation dollars combined with discretionary dollars was .13, while the federal range ratio for the foundation dollars combined with those generated through the capital outlay and maintenance rates was .24. The federal range ratio calculated for the distribution of revenues from all three sources examined in this study was 29. The preceding discussion included the results of the calculations relevant to the effects of the discretionary revenues on the resource accessibility of the foundation program. Following is a presentation of the results of the calculations of the wealth neutrality measures. wealth Neutrality Wealth neutrality refers to the extent to which resources available for the education of students is not related to local fiscal conditions of the area in which the student is educated. Typical assessments of wealth neutrality include regression related measures, including the correlation coefficient, coefficient of determination, and
PAGE 133
125 regression coefficient. Additionally, two econometric measures, the Gini coefficient and McLoone index, may be used to measure the wealth neutrality of educational funding distribution systems. The following section includes the results of the wealth neutrality calculations. The regression related measures of wealth neutrality are included in Table 3. The correlation coefficient resulting from correlating per-pupil local assessed value of property and per-pupil revenues derived from the foundation program was .50. Thus, a positive association existed between local wealth as represented by per-pupil property value and the resources for educational support as represented by per-pupil foundation revenues With the discretionary funding source, the correlation coefficient was 99 and for the capital outlay and maintenance source .94. These relatively high correlation coefficients were not surprising given the fact that the revenues were determined through application of millage rates on assessed valuation of property The correlation coefficient for the combination of the discretionary and capital outlay and maintenance funding sources was 99. The addition of revenues from both the discretionary and capital outlay and maintenance revenue sources resulted in rather substantive i ncreases in the relationship between district property wealth and revenues per-pupil as demonstrated through the correlation coefficient
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calculations The foundation plus discretionary source correlation coefficient was calculated at 85, while the foundati o n plus capital outlay and maintenance source correlation coefficient was calculated at .97. The correlation coefficient for all three sources was .99. Table 3 Wealth Neutrality: Regressi o n Measures Found Disc Cap D + C F + D F + C F + D + C Correlation Coefficient .50 .99 94 .99 .85 .97 .99 Coefficient of Determination .25 .99 .88 98 72 .94 .98 Regression Coefficient .00034291 .00057916 .00172990 .00228479 .00092207 .00204854 .00262770 126 The coefficient of determination was useful in understanding the relationship as demonstrated by the correlation coefficients. The coefficient of determination measured the proportion of the variability of per-pupil revenues which was explained by the variability of per-pupil assessed valuation. Local per-pupil assessed valuation variability accounted for .25 of the variability in per-pupil
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127 foundation revenues, .99 of the variability in per-pupil revenues generated through the discretionary millage rate, and .88 percent of the variability in revenues generated through the capital outlay and maintenance rate. Local per pupil assessed valuation variability explained .98 of the variability in per-pupil revenues generated through the combination of both unequalized sources. The coefficient of determination for per-pupil revenues derived from the foundation program combined with current operation discretionary revenues was calculated at .72. The foundation dollars in combination with the capital outlay and maintenance dollars resulted in a coefficient of determination of .94. When all three sources were considered, the percent variation in revenues per-pupil explained by per-pupil assessed valuation was .98. The correlation coefficients and coefficients of determination provided measures of the strength of relationship between per-pupil assessed valuation and per pupil revenues generated across the seven levels of aggregation. The regression coefficients provided a indication of the magnitude of the relationship between the variables across the levels. The following section includes the results of the calculations of the regression coefficients. The regression coefficient for the foundation revenues was .00034291. The interpretation for this measure is that
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128 for every dollar increase in the independent variable assessed valuation per-pupil, there was an associated increase of $.00034291 in per-pupil revenues. The regression coefficient for discretionary revenues was .00057916, for capital outlay and maintenance revenues was .0017299, and for the combination of the unequalized dollars was .00230648. The regression coefficient resulting from the combination of foundation and discretionary revenues was .00092207, and for the combination of foundation revenues and those originating from the capital outlay and maintenance rates was .00204854. The regression coefficient for the revenues emanating from all three sources in combination was 0026277 The preceding were results of the regression measures of wealth neutrality. Additionally, two econometric measures of wealth neutrality, the McLoone index and Gini coefficient, were calculated at each aggregation level. The results of these calculations are included in Table 4. The McLoone index indicates the proportion of per-pupil revenues for districts below the median to the amount necessary to bring all these districts to the median level. T-he McLoone index for foundation revenues was calculated at .98. For current operation discretionary dollars the McLoone index was .73 and was .67 for capital outlay and maintenance revenues. The dollars generated through the combination of
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discretionary and capital outlay and maintenance revenues resulted in a McLoone index of .70. T.able 4 Wealth Neutrality: Econometric Measures McLoone Index Gini Coefficient Found .98 .01 Disc .73 .12 Cap .67 .13 D + C .70 .12 F + D 98 .01 F + C .97 .02 F + D + C .97 .02 129 The McLoone index for foundation revenues combined with current operation discretionary revenues was .98, virtually the same as for the foundation dollars alone The McLoone index for foundation plus capital outlay and maintenance revenues, .97, was not much lower. The McLoone index for revenues generated from a combination of all three sources was calculated at .97. The Gini coefficient is a quantitative measure of the extent to which the distribution of per-pupil revenues is constant across pupils. The Gini coefficient for foundation revenues was.01, for current operation discretionary revenues
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130 .12 and for capital outlay and maintenance revenues 13 The Gini coefficient resulting from the combination of both unequalized millage rates was .12. The Gini coefficient calculated from the combination of per-pupil revenues of the foundation program with per-pupil discretionary revenues remained at .01. The Gini coefficient for foundation revenues and capital outlay and maintenance revenues per-pupil was .02, while the Gini coefficient calculated for revenues from all three sources was also .02. The preceding calculations represented measurement of the effects of discretionary levies on the wealth neutrality of a foundation program. Another aspect of fiscal equity, tax yield, was measured in the present study. Following are the results of the tax yield measures. Tax Yield Tax yield is a taxpayer equity construct involving the measurement and analysis of the association between tax effort and resultant resources. In the present study two measures, correlation and regression, were used to measure the relationship between tax effort and resources across the seven levels of aggregation. Tax effort was represented by the per-pupil millage rate applied at each level, while resources was represented by per-pupil revenues resulting from these millage rates The tax yield results for the present study are included in Table 5.
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Table 5 Tax Yield Found Disc Cap D + C F + D F + C F'. + D + C Correlation Coefficient +.17 -.12 -.28 -.37 -.03 -.49 -.48 Regression Coefficient +13769.96 -83410.47 -198389.24 -268342.81 -2799.73 -75477.85 -83871. 06 131 A correlation coefficient of .17 was calculated for the foundation program funding source. This indicated that increasing tax rates were associated with slightly increasing per-pupil revenues. Both the discretionary level (. 12) and capital outlay and maintenance level (-.28) demonstrated inverse relationships between tax effort and revenues per pupil, meaning that increasing tax effort was associated with decreased per-pupil revenues. The combined unequalized tax effort correlated (-.37) with resultant per-pupil revenues. When combined with the foundation program funding source, the two unequalized sources had clear effects on tax yield. The foundation plus discretionary sources per-pupil
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132 millage rates correlated (-.03) with per-pupil revenues resulting from these rates, while foundation millage rates combined with capital outlay and maintenance rates correlated (-.49) with resultant per-pupil revenues. The combined perpupil millage rates from all three sources correlated (-.48) with total per-pupil revenues. The correlation coefficients indicated the strength of the relationship between per-pupil millage rates and per pupil revenues for each level of examination. The magnitude of the relationship was measured through regression coefficients. For the foundation program, the regression coefficient was measured at $13769.96. This indicates the magnitude with which higher levels of tax effort were associated with lower levels of revenues per-pupil. The regression coefficient calculated for discretionary effort and yield was (-$83410.47), and for capital outlay and maintenance effort and yield was (-$198389.24). The combination of discretionary with capital outlay and maintenance effort and yield resulted in a regression coefficient of (-$268342.81). The regression coefficient for the combination of foundation program with discretionary effort and yield was calculated at (-$2799.73). The combination of the foundation yield and effort with capital outlay and maintenance yield and effort resulted in a regression coefficient of
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133 (-$75477 85). Lastly ; when per-pupil yield involving all three millage rates was regressed on per-pupil revenues from all three sources, the resultant coefficient was (-$83871. 06) conclusion In this chapter the results of the a q alysis intended to address the question, "In a state with a foundation program for support of schools including one or more discretionary millage rates, to what extent do the levies resulting from the application of the discretionary millage rates introduce inequities into the system for distributing education funding?" were presented. These results were related to three constructs of fiscal equity, including resource accessibility, wealth neutrality, and tax yield. The resource accessibility issue was addressed using descriptive measures of per-pupil revenues, including the mean, range, restricted range, federal range ratio, variance, standard deviation, and coefficient of variation. The wealth neutrality issue was addressed using both regression and econometric measures. The regression measures included the correlation coefficient, coefficient of determination, and regression coefficient, in which the relationship between per-pupil assessed valuation and per pupil revenues was calculated. The econometric measures included the Gini coefficient and McLoone index, which
PAGE 142
134 included analysis of the distribution of per-pupil revenues. The tax yield issue was addressed using regression measures, in which the relationship between tax effort and per-pupil r.evenues was measured using the correlation coefficient and regression coefficient. Chapter 5 includes a discussion of the results, including overall conclusions and implications of the study. Notes 1 Division of Public Schools, 1992-93 Florida Education Finance Program (Tallahassee, FL: Florida Department of Education, 1992).
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CHAPTER 5 DISCUSSION In Chapter 4 the results of the analysis related to the research question, "In a state with a foundation program for support of schools including one or more discretionary millage rates, to what extent do the levies resulting from the application of the discretionary millage rates introduce inequities into the system for distributing education funding?" were presented. Chapter 5 includes a discussion of these results. The current chapter begins with a general summary of the study. Subsequent to this general summary observations are presented based on the results obtained in Chapter 4. The discussion then turns to the conclusions reached based on these observations, specifically in light of the concepts of equity discussed in Chapter 2. Chapter 5 concludes with implications of the study for further research and practice. summary The constitutions of the respective states specify that education is a state responsibility. State governments by and large are compelled by the respective state constitutions to aspire toward equity as it relates to fiscal support for 135
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136 education. As a result most states have attempted to fund the educational enterprise though a methodology that promotes equity in the distribution of resources among local education agencies. The most common method of promoting equity has been through a state foundational system of distribution. Such a system ensures each local district, and therefore each student, a certain foundational level of educational support conceivably relevant to his or her educational needs. The foundation program theoretically provides the assurance that no student falls below a certain basic level of funding However, the basis for a foundation program is provision of a minimally acceptable level of fiscal support for all children. Typically, local districts are allowed the option to exert additional taxing effort to raise additional revenues for further support of education beyond the foundational level. Thus, in theory state support programs which include a foundational element may allow some degree of inequity to exist, given the basic level of support concept inherent in the program. The degree to which certain inequities above the foundation level are tolerable have been adjudicated in several of the court systems of states which utilize such a support system. Unfortunately, no consistent pattern of court decisions exists with regard to the the extent to which the existence of some inequity is constitutionally acceptable Court decisions in the respective state court
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137 systems have been mixed in terms of the constitutionality versus unconstitutionality of state foundation systems in right of the various standards of equity, while federal courts have refused to strike down education finance systems. Without clear guidance from the courts, states have dealt with the problem of revenues generated beyond the foundation level differently. Some states simply provide an equalized foundation program and allow the additional revenues to remain unequalized. Other states have utilized various methods of equalizing the revenues generated beyond the foundation system. The state of Florida employs a foundation system as the core of its state system of fiscal support for education. Yet, the revenues generated through the two nonvoted sources beyond the foundation system are not equalized by the state. The foundation portion of the FEFP has been demonstrated to exhibit a large degree of distributional equity. A reasonable question to address, therefore, is to what extent do these local discretionary elements of the program introduce disequalizing effects into the system as a whole. This question was the subject of the current study. observations The previous section included a general summary of the present study. The current section includes observations
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based on the results of the study that were presented in Chapter 4 138 The introduction of unequalized revenues into foundation program revenues had the effect of increasing the variation in the per-pupil levels of support. This increase was evident given the increases of variance calculations and ~tandard deviations, which demonstrate aggregate dollar variability increases. Standardized variability calculations, specifically those related to the coefficient of variation, demonstrated virtually no increase in the variability g i ven the introduction of discretionary dollars. An increase in standardized variability, however, was evident as capital outlay and maintenance revenues were introduced into the distribution. Clearly, the range estimates increased as unequalized revenues are introduced into the distribution, a result that was expected because the total aggregate dollars were increasing as more revenues were involved. Both the range and restricted range calculations demonstrated increases as both discretionary and capital outlay and maintenance revenues were included in the distribution, both individually and together. Introduction of the discretionary dollars resulted in an increase of the federal range rat i o by almost a third, while capital outlay and maintenance revenues resulted in the federal range ratio being increased by a factor of two and a half.
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139 Regression measures of wealth neutrality demonstrated notable disequalizing effects of both the discretionary and capital outlay and maintenance revenues as they were combined with the revenues obtained through the foundation program. The discretionary combined with foundation revenues per-pupil demonstrated a strong positive relationship to per-pupil property wealth, while the revenues derived from foundation and capital outlay and maintenance sources had an extremely strong relationship to per-pupil property wealth. The strength of the relationship between per-pupil property wealth and per-pupil revenues virtually doubled from the foundation only revenues to revenues derived from all three sources in combination as measured by the correlation coefficient. The addition of the discretionary and capital outlay and maintenance sources had the effect of increasing the amount of variance in per-pupil revenues explained by variance in per-pupil property wealth. When examining the foundation source alone, variance in per-pupil assessed valuation explained only one-quarter of the variance in per-pupil foundation revenues. However, per-pupil property wealth explained nearly three-fourths of the variation in foundation combined with discretionary revenues per-pupil and nearly all of the variance in foundation combined with capital outlay and maintenance revenues per-pupil. Per-pupil assessed valuation likewise explained nearly all variation in per
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140 pupil revenues obtained through the combination of all three sources The distribution of the foundation revenues demonstrated a large degree of wealth neutrality as demonstrated by the Gini Coefficient. The addition of the discretionary revenues had virtually no effect on the foundation program as evidenced by the Gini coefficient calculated for these two revenue sources. The addition of the capital outlay and maintenance revenues had the effect of increasing the Gini coefficient, whether combined with foundation revenues or with both foundation and discretionary revenues. The distribution of per-pupil revenues through the foundation program below the median demonstrated a high degree of wealth neutrality as evidenced by the McLoone Index The addition of the discretionary revenues to the foundation program had virtually no effect on the distribution below the median, with the McLoone index remaining constant as these revenues were added to foundation program revenues. The addition of the capital outlay and maintenance revenues to the foundation revenues and to both foundation and discretionary revenues had negligible effects on the wealth neutrality of the distribution below the median as evidenced by the McLoone index calculations. A weak positive relationship between taxpayer effort and resultant educational resources generated through the foundation program was demonstrated through calculation of
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141 the tax yield measures. The addition of discretionary funding had the effect of eliminating this relationship, therefore decreasing equality of tax yield. The combination of the capital outlay and maintenance with foundation sources resulted in the relationship between tax effort becoming inverse. With capital outlay and maintenance funding included in the distribution, increasing tax effort was associated with decreasing per-pupil revenues generated for ~ducation. This inverse relationship was true whether the foundation and capital outlay and maintenance sources were considered or all three sources in combination were considered. conclusions The preceding section included observations based on the analysis of these data. The following section includes overall conclusions about the disequalizing effects of the discretionary and capital outlay and maintenance funding sources based on these observations. In the realm of resource accessibility, both the discretionary revenues and capital outlay and maintenance demonstrated disequalizing effects when considered in combination with foundation revenues as indicated by both the measures of range and measures of variability. Increases in both range indicators and variability indicators of resource accessibility was not surprising, however, given the fact
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142 that more dollars were involved as additional revenue sources are added to the analysis. In fact, the standardized calculation of variability, the coefficient of variation, demonstrated the least profound disequalizing effects of the two additional sources. In both the range indicators and the variability indicators, the capital outlay and maintenance source had greater disequalizing effects than the discretionary source. Both the discretionary and capital outlay and maintenance funding sources resulted in decreased wealth neutrality when added to the foundation sources, as indicated by the relationship between per-pupil wealth and per-pupil revenues. The capital outlay and maintenance funding source caused a much more acute decrease in wealth neutrality than the discretionary source. In fact, the relationship between per-pupil wealth and per-pupil revenues including the capital outlay and maintenance source is virtually a direct relationship. The two additional funding sources demonstrated less pronounced effects on wealth neutrality as measured by univariate econometric methods (Gini coefficient and McLoone Index) The effects on wealth neutrality below the median were relatively slight, as evidenced by the McLoone index. Once again, the revenues generated through the capital outlay and maintenance source have more disequalizing effects on the
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distribution than those raised through the discretionary source. 143 Both sources result in disequalizing effects in the realm of taxpayer equity The inclusion of the discretionary source tended to eliminate the positive relationship between per-pupil tax effort and per-pupil revenues that existed when the foundation source was considered alone. The capital outlay and maintenance source had far greater effects; the inclusion of this source resulted in a negative relationship between per-pupil tax effort and per-pupil revenues raised. Implications The previous section included conclusions based on the results of this study. The current section includes a discussion of implications of this study for further research and practice. Further investigation into issues closely related to those examined in the present study is certainly warranted due to the significance of these issues. Chapter 2 included a summary of state programs which allow for equalization of discretionary revenues, generally through a guaranteed tax base or guaranteed yield program. A study which looks at such a second tier equalization program for the FEFP discretionary elements would be a natural extension of the present study. Included could be an analysis of the degree to which the system maintains the high degree of equity
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144 inherent in the foundation element, while examining the cost of maintaining such equity. Examinations relevant to the discretionary millage revenues, capital outlay and maintenance revenues, or the combination could be undertaken accordingly. This study provided a thorough analysis of the effects of discretionary levies on the equity of a foundation program of state support. However, further study into the adequacy of the system is needed. Specifically, the Florida Constitution requires that "adequate provision shall be made for a uniform system of free public schools." 1 The current study addressed the uniform provision, involving equity of the distribution of educational dollars throughout the state. Further examination into the "adequate provision" requirement may be beneficial. The study examined disequalizing effects of the discretionary levy, the funds derived from which may be used to support current operation of education. 2 The capital outlay and maintenance revenues, which are restricted by state statute, 3 were also examined. Further study into the specific nature of funding in this area may also be useful. In other words, to what extent are these revenues significant to the educational enterprise in the schools? Such a research question may help in understanding the extent to which those states that use a foundation system and have
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145 additional millage rates for capital financing purposes may be said to be subject to truly disequalizing effects. The present study addressed the effects of two nonvoted discretionary millage rates. Examinations of the effects on fiscal equity of the two voted millage rates, one which may be levied for current operation and the other for debt service, 4 may be beneficial. The present study included an examination into the fiscal equity of state funding among Florida school districts. This study therefore by its nature included a macroanalysis of a foundation distribution system. A microanalysis might also be part of a viable study, which would address the equity of the distribution of funds among individual schools. Such a study would include a picture of intradistrict fiscal equity, as opposed to the interdistrict examination included in the present study. The present study included an exhaustive analysis of the effects of local discretionary millage rates on the foundation program used to finance Florida public elementary and secondary schools. Certainly similar studies in other states utilizing a foundation program to support public education in which discretionary levies are included are warranted. Any of the preceding suggested studies would be worthwhile in enlightening researchers and practitioners in the area of education finance. Certainly, such enlightenment
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146 is warranted given the significance of providing appropriate fiscal support for a quality education for all children. Notes 1 Fla. Const. art. VII sec. 9(a). 2Fla. Stat. 236.25(1). 3Fla. Stat. 236.25(2). 4Fla. Stat. 200.001(3).
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APPENDIX A 1992-93 FEFP PROGRAM COST FACTORS Baaic Program Kindergarten and Grades 1, 2, and 3 Grades 4, 5, 6, 7, and 8 Grades 9, 10, 11 and 12 Mainstream Grades K-3 Grades 4-8 Grades 9-12 Program for At-Riak Student Dropout Prevention Intensive English/ESOL K-3 Intensive English/ESOL 4-8 Intensive English/ESOL 9-12 Bxceptional Student Program 1992-93 flctora 1.014 1.000 1. 225 2.028 2 000 2 450 1. 656 1.644 1.679 1 649 Educable Mentally Handicapped 2 184 Trainable Mentally Handicapped 2.922 Physically Handicapped 3.453 Physical & Occupational Therapy, Part-Time 9.527 Speech, Language, and Hearing Therapy, Part-Time 5 475 Speech, Language and Heari ng 3 176 Visually Handicapped, Part-Time 15 145 Visually Handicapped 4.353 Emotionally Handicapped, Part-Time 3 740 Emotionally Handicapped Specific Learning Disability, Part-Time Specific Learning Disability Gifted, Part-Time Hospita l & Homebound, Part-Time Profoundly Handicapped Adult General Education Program Adult Basic Skills Adult Secondary Education Lifelong Learning Adult Disabled Vocational-Technical Program Job Preparatory 1-=..il MlU.t A griculture l. 728 1. 537 Business and Office 1.229 1. 292 D i s tributive 1.112 1. 374 Diversified 1.185 .877 H ealth 1.513 .506 Public Service 930 .959 Horne Economics 1. 261 1 433 Industrial 1 746 1. 418 Exploratory (Grades 6-12) 1. 276 Vocational Mainstream 2.325 2 812 2 914 2 049 1.896 11 611 4 396 .745 763 700 1 337 Adult supplemental 1. 516 1 114 806 1 454 1.060 1. 367 1. 332 Source: Laws of Florida 92-293 item 516. 147
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APPENDIX B RAW DATA DISTRICT RLE Mill Dis Mill Cap Mill WFTE 92 Tax Roll Alachua 6.6000 0.510 0.6650 34363.36 $3,478,806,917 Baker 6.6740 0.510 2.0000 5638.30 $203,172,343 Bay 6.6000 0.510 0.9820 30808.57 $3,795,133,278 Bradford 6.7060 0.510 1. 5000 5263.75 $302,394,024 Brevard 6.4920 0.510 2.0000 74343.45 $13,222,913,419 Broward 6.6890 0.510 2.0000 255738.60 $48,030,220,202 Calhoun 6.6780 0.000 0.0000 2746.04 $148,560,257 Charlotte 6.4910 0.510 1. 2426 18080.74 $5,953,284,806 Citrus 6.7330 0.510 2.0000 16229.15 $3,584,008,767 Clay 7 .0170 0.510 2.0000 27819.02 $2,560,042,477 Collier 5.7430 0.510 1.7470 31270.45 $14,546,382,399 C-olumbia 6.4940 0.510 2.0000 10389.28 $672,339,379 Dade 6. 7130 0.510 1. 8000 435842.50 $65,960,000,000 De Soto 6.6000 0.510 1.5000 5637.27 $563,429,292 Dixie 6.7490 0.510 2.0000 2530.99 $168,357,071 Duval 6.4930 0.510 1.7990 146121.90 $18,967,436,166 Escambia 6.9750 0.510 2.0000 60560 51 $5,230,986,632 Flagler 6.4930 0.510 1.0000 6478.80 $2,009,940,591 Franklin 6.6520 0.510 0.1890 1968.49 $330,222,577 Gadsden 6.6550 0.510 2.0000 10355.10 $470,097,137 Gilchirst 6.4930 0.510 2.0000 2659.61 $153,229,270 Glades 6.8030 0.510 1. 4000 1147 .11 $340,092,453 Gulf 6.5750 0.510 0.2050 2735.36 $518,114,292 Hamilton 6.7860 0.510 0.9090 2839. 77 $320,766,531 Hardee 6.4930 0.510 1. 8000 6154.27 $542,297,841 Hendry 6.4960 0.510 2.0000 7681. 05 $1,087,719,471 Hernando 6.7600 0.510 1.1710 17050. 08 $3,118,144,088 Highlands 6.7310 0.510 1. 6390 12939.38 $2,078,389,640 Hillsboro 6.7230 0.510 2.0000 179306.20 $23,878,301,787 Holmes 6. 5110 0.000 0.0000 4141. 29 $160,952,311 Indian Ri 6.5810 0.510 1.5283 15462.45 $5,160,114,845 Jackson 6. 7240 0.510 0.0000 11082.06 $527,890,754 Jefferson 6.4930 0.510 0.7500 2708.36 $190,317,324 Lafayette 6.6700 0.510 2.0000 1262.06 $83,518,770 Lake 6.4950 0.510 2.0000 28531.06 $4,273,371,924 Lee 6.6910 0.510 2.0000 59349.72 $18,800,716,150 Leon 6.4940 0.510 2.0000 41293.80 $4,775,685,713 Levy 6.4950 0.510 2.0000 6607.99 $566,145,772 Liberty 6.9220 0.510 0.0000 1481.31 $84,118,010 Madison 6.5680 0.510 0.0000 4007.51 $222,493,571 Manatee 6.5050 0.510 2.0000 37127.97 $8,159,607,470 Marion 6.6450 0.510 1.0000 39570.57 $4,861,806,224 Martin 6.1560 0.510 1. 6900 17224.81 $7,319,424,936 148
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149 Monroe 5.0000 0.510 0.1970 11519. 42 $6,514,269,506 Nassau 6.5870 0.510 2.0000 10601.30 $1,647,307,917 Okaloosa 6.6320 0.510 1.3000 33451.39 $3,489,704,869 Okeechobe 6.4910 0.510 2.0000 7621. 30 $764,287,540 Orange 6.4930 0.510 2.0000 145712.90 $32,261,619,201 Osceola 6.4930 0.510 2.0000 27511.64 $4,471,525,576 Palm Beac 6.4960 0.510 2.0000 162107.30 $51,030,744,544 Pasco 6.5740 0.510 1. 5030 47364.47 $6,961,601,855 Pinellas 6.4900 0.510 2.0000 136565. 50 $29,572,044,680 Polk 6.5610 0.510 1. 4130 87232.04 $10,792,982,876 Putnam 6 6510 0.510 0.0000 14843.76 $1,926,565,256 St. Johns 6.4930 0.510 1. 5000 18856.94 $3,813,970,113 St. Lucie 6.4930 0.510 2.0000 29244.81 $6,867,017,584 Santa Rosa 6.6320 0 .110 1. 4000 21135 .17 $2,100,751,939 Sarasota 6.5620 1.019 2.0000 43522.73 $14,931,123,231 Seminole 6.4930 0.510 2.0000 62148. 04 $9,970,948,164 Sumter 6.8310 0.510 2.0000 6537.74 $477,986,406 Suwannee 6.4970 0.510 2.0000 6939.02 $429,891,014 Taylor 6.4930 0.510 2.0000 4728.61 $562,380,155 Union 6.4930 0.510 1. 5000 2500.85 $82,190,841 Volusia 6.4920 0.510 1.0500 65682.33 $11,922,873,987 Wakulla 6.9020 0.510 2.0000 4491. 72 $250,373,159 Walton 6.4950 0.428 1. 4500 5605.22 $1,372,448,816 Washington 6.6310 0.510 0.0000 4916.63 $256,872,437 TOTALS 2645391 $479,892,428,547 DISTRICT State Fnd Rev RLE Rev Tot Found Rev Alachua $67,972,347 $21,831,138 $89,803,485 Baker $13,472,776 $1,311,453 $14,784,229 Bay $57,038,753 $24,054,360 $81,093,113 Bradford $12,157,298 $1,978,705 $14,136,003 Brevard $117,901,108 $81,550,996 $199,452,104 Broward $398,843,006 $307,496,733 $706,339,739 Calhoun $6,351,194 $945,735 $7,296,929 Charlotte $10,937,516 $37,067,682 $48,005,198 Citrus $20,255,961 $23,139,088 $43,395,049 Clay $55,833,897 $17,082,058 $72,915,955 Collier $6,840,013 $79,630,197 $86,470,210 Columbia $23,165,150 $4,150,178 $27,315,328 Dade $778,381,756 $423,247,923 $1,201,629,679 De Soto $11,461,685 $3,723,639 $15,185,324 Dixie $5,903,145 $1,084,036 $6,987,181 Duval $266,270,768 $116,997,785 $383,268,553 Escambia $122,832,603 $35,030,970 $157,863,573 Flagler $5,127,817 $12,507,135 $17,634,952 F,ranklin $3,578,556 $2,087,227 $5,665,783 Gadsden $24,893,545 $3,091,940 $27,985,485 Gilchirst $6,645,060 $947,966 $7,593,026 Glades $1,112,460 $2,199,740 $3,312,200 Gulf $4,553,601 $3,237,207 $7,790,808
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150 Hamilton $5,866,676 $2,068,458 $7,935,134 Hardee $12,916,437 $3,350,674 $16,267,111 Hendry $14,036,159 $6,733,161 $20,769,320 Hernando $25,643,121 $20,052,749 $45,695,870 Highlands $21,439,484 $13,290,159 $34,729,643 Hillsboro $312,282,987 $153,839,161 $466,122,148 Holmes $10,374,661 $995,562 $11,370,223 Indian Ri $8,752,152 $32,311,482 $41,063,634 Jackson $26,359,540 $3,376,897 $29,736,437 Jefferson $6,161,443 $1,175,250 $7,336,693 Lafayette $3,049,267 $529,217 $3,578,484 Lake $47,935,154 $26,674,847 $74,610,001 Lee $34,774,937 $120,127,349 $154,902,286 Leon $76,953,706 $29,983,629 $106,937,335 Levy $14,745,879 $3,503,984 $18,249,863 Liberty $3,535,190 $553,152 $4,088,342 Madison $9,433,200 $1,388,271 $10,821,471 Manatee $48,257,490 $50,673,287 $98,930,777 Marion $73,030,612 $30,836,850 $103,867,462 Martin $4,094,002 $42,953,658 $47,047,660 Monroe $3,765,645 $30,959,083 $34,724,728 Nassau $18,350,961 $10,312,006 $28,662,967 Okaloosa $66,416,421 $22,250,197 $88,666,618 Okeechobe $14,632,042 $5,386,969 $20,019,011 Orange $187,625,033 $201,039,228 $388,664,261 Osceola $44,516,436 $27,687,385 $72,203,821 Palm Beac $126,088,619 $324,563,960 $450,652,579 Pasco $80,941,198 $43,579,846 $124,521,044 Pinellas $177,530,622 $183,812,608 $361,343,230 Polk $159,690,707 $68,140,789 $227,831,496 Putnam $27,605,489 $12,172,906 $39,778,395 St Johns $25,444,171 $24,045,476 $49,489,647 St. Lucie $35,002,102 $42,358,168 $77,360,270 Santa Rosa $42,761,140 $13,321,786 $56,082,926 Sarasota $22,623,832 $93,630,685 $116,254,517 Seminole $100,485,690 $61,504,298 $161,989,988 S\.unter $14,513,263 $3,110,168 $17,623,431 Suwannee $16,037,571 $2,702,417 $18,739,988 Taylor $9,096,620 $3,534,882 $12,631,502 Union $6,470,159 $506,982 $6,977,141 Volusia $99,938,262 $73,533,133 $173,471,395 Wakulla $10,347,481 $1,649,324 $11,996,805 Walton $7,173,923 $8,472,952 $15,646,875 Washington $11,338,261 $1,961,421 $13,299, 682 TOTALS $4,089,567,760 $3,009,048,357 $7,098,616,117
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REFERENCES Agresti, Alan and Barbara Finlay Agresti, Statistical Methods for the Social Sciences (San Fransisco: Dellen Publishing Co., 1979). Alexander, Kern and Lee Shiver, "Equalization Among Florida school Districts," Journal of Education Finance 9 (Summer, 1983), 55-62. Anderson, T.W. and Stanley L. Sclove, The Statistical Analysis of Data, 2nd ed. (Palo Alto, CA: The Scientific Press 19 8 6 ) Berne,Robert, "Equity Issues in School Finance," Journal of Education Finance 14 (Fall 1988). Robert Berne and Leanna Stiefel, "Equity Standards for State School Programs: Philosophies and Standards Relevant to Section 5(d) (2) of the Federal Impact Aid Program," Journal of Education Finance 18 (Summer, 1993), 89-112. Berne, Robert and Leanna Stiefel, The Measurement of Equity in School Finance (Baltimore: The Johns Hopkins University Press, 1984). Burrup, Percy E., Vern Brimley, Jr, and Rulon Garfield, Financing Education in a climate of Change. 4th ed. (Boston: Allyn and Bacon, Inc., 1988). Carroll, Stephen J., The search for Equity in School Finance: Results from Fiye States. (Santa Monica, CA: The Rand Corporation, 1979). Carroll, Stephen J. and Rolla E. Park, The Search for Equity in School Finance (Cambridge, MA. : The Ballinger Press, 1983) Chaterjee, Samprit and Bertram Price, Regression Analysis by Example. 2nd ed. (New York: John Wiley & Sons, inc., 1991) cubberley, Ellwood P., school Funds and Their Apportionment (New York: Columbia University, 1906). 151
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152 Currie, Gaylon D., An Examination of the EQUity of Capital outlay Funding of Public Education: A comparison of the E@ity of the current Method of Distributing capital outlay Funding in the state of Florida and the EQUity of General Expenditures for Education. {Doctoral Dissertation, University of Florida, 1992). Division of Public Schools, 1992-93 Florida Education Finance Program {Tallahassee, FL: Florida Department of Education, 1992). Division of Public Schools, Profiles of Florida school Districts 1992-93 student & staff Data {Tallahassee, FL: Florida Department of Education, 1992). Florida Constitution. Florida Statutes 1992. Georgia Code 1992. Gold, Stephen D., David M. Smith, Stephen B Lawton, and Andrea c. Hyary {eds.), Public school Finance Programs of the united states and Canada. 1990-91. vol. 1 {Albany, NY: Center for the Study of the States, 1992). Guthrie, James W., Walter I. Garms, and Lawrence C. Pierce, school Finance and Education Policy: Enhancing Efficiency, EQUality, and Choice, 2nd ed. {Englewood Cliffs, NJ: Prentice-Hall, 1988). Johns, Roe L. and Richard G. Salmon, "The Financial Equalization of Public Schools Support Programs in the United States for the School Year 1968-69," Status and Impact of Educational Finance Programs {Gainesville, FL: National Education Finance Project, 1971). Johns, Roe L., Edgar Morphet, and Kern Alexander, The. Economics and Financeing of Education. 4th ed. {Englewood Cliffs, NJ: Prentice Hall, 1983). Jones, Thomas H., Introduction to School Finance (New York: Macmillan Publishing Company, 1985). Kentucky Revised Statutes Annotated 1992. Laws of Florida 1992. Montana Code Annotated 1992.
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Monk, David H., Educational Finance: An Economic A:Qoroach (New York : McGraw-Hill, 1990) 153 Morphet, Edgar "Characteristics of State Support Programs," in R.L. Johns (ed.), Problems and Issues in school Finance (New York: National Conference of Professors of Educational Administration, 1952). Morrison, Henry c. School Revenue (Chicago, IL: University of Chicago Press 1930). Mort, Paul R The Measurement of Educational Need (New York: Teachers College, Columbia University, 1924). Mort, Paul R., State suooort for Public Schools (New York: Teachers College, 1926). Mort, Paul R., state suooort for Public Education (Washington, DC: The American Council on Education, 1933). Mort Paul R. and Walter c. Reusser, Public School Finance (New York: McGraw-Hill Book Company, Inc., 1941). Mort, Paul R., Walter c. Reusser, and John w Polley, Public school Finance; Its Background, structure, and ooeration (New York: McGraw-Hill Book Company, Inc ,1960). National Center for Educational Statistics, Digest of Education statistics (Washington, DC: u s. Department of Education, 1992). Oklahoma School Code 1992 O'Loughlin, J. Michael, R. Craig Wood, and Davids. Honeyman, A study of the Effects of the soarsity suoolement on the Equity of the Florida Education Finance Program (Gainesville, FL: UCEA Center for Education Finance, 1992) President's Commission on School Finance, Review of Existing State school Finance Programs (Washington, D.C.: united States Government Printing Office, 1972). Sparkman, William E., "School Finance Challenges in State Courts," in Julie K Underwood and Deborah A. Verstegen (eds ), The Imacts of Litigation and Legislation on Public school Finance (New York: Harper & Row, 1990).
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154 Stark, Steven, Davids. Honeyman, and R. Craig Wood, "The Florida Lottery: Its Use as a Substitute for Existing Funds and its Effects on the Equity of School Funding," Journal of Education Finance 18 (Winter, 1993), 231-242. Stark, Steven D., David S. Honeyman, and R. Craig Wood, An Examination of the Florida Lottery (Gainesville, FL: UCEA Center for School Finance, 1991). Stellar, Arthur W., "Implications for Programmatic Excellence and Equity," in Van D. Mueller and Mary P. McKeown (eds.), The Fiscal, Legal, and Political Aspects of Elementary and secondary Education (Cambridge, MA: Ballinger, 1986). Strayer, George D. and Robert M. Haig, The Financing of Education in the state of New York. vol. 1 (New York: Macmillan, 1923). Swanson, Austin D. and Richard A. King, School Finance: Its Economics and Politics (New York: Longman, 1991) Texas Education Code Annotated 1992. Thompson, David C., R. Craig Wood, and David S. Honeyman, Fiscal Leadership for schools: concepts and Practices. (White Plains, NY: Longman Publishing Group, 1994). Underwood, Julie K. and Deborah A. verstegen, "School Finance Challenges in Federal Courts: Changing Equal Protection Analysis," in Julie K. Underwood and Deborah A. verstegen (eds.), The rmacts of Litigation and Legislation on Public school Finance (New York: Harper & Row, 1990) Updegraff, Harlan, Rural school survey of New York state: Financial support (Ithca, NY: The Joint committee on Rural Schools, 1922). U.S. Constitution. Vaughan, David, "The Impact of Florida's 1973 School Finance Reform on Poor and Minority Children," in Robert Brischetto (ed.), Minorities, the Poor, and school Finance Reform (Washington: National Institute of Education, 1979). Verstegen, Deborah A School Finance at a Glance (Denver, CO: Education Commission of the States, 1990).
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155 ward, James Gordon and William E. Camp, "An Analytic View of Two Decades of Reform in School Finance: Some Comments," Journal of Education Finance 14 (Summer, 1988), 1-17. Webb, L. Dean, Martha M. McCarthy, and Stephen B. Thomas, Financing Elementary and secondary Education (Columbus: Merrill Publishing Co., 1988). Wood, R. Craig and David S. Honeyman, "Rapid Growth and Unfulfilled Expectations: Problems for School Finance in Florida," in James Gordon Ward and Patricia Anthony (eds.), Who Pays for Student Diversity? (Newbury Park, CA: Corwin Press, Inc., 1992). wood, R. Craig and David c. Thompson, Education Finance Law; constitutional challenges to state Aid Plans: An Analysis of Strategies (Topeka, KS: National Organization of Legal Problems in Education, 1994). Legal citations Board of Education of city school District, etc, v, Walter, 390 N.E.2d 813 (1980). Board of Education, Levittown, etc. v. Nyquist. N.Y., 439 N.E.2d 359 (1982). Carrollton-Farmers Branch Independent school Dist. v. Texas. 826 S.W.2d 489 (1992). Christensen v. Graham, Dist. court of App., case No. 88-69. Dupree v, Alma school District no. 30, 651 s.w.2d 90 (1983). Edgewood Independent school District v. Kirby. 777 s.w. 2d 391 (1989). Fair school Finance council of Oklahoma, Inc. v. Oklahoma. 746 P 2d 1135 (1987). Florida Department of Education v. Glasser, 622 so.2d 944 (Fla. 1993). Helena Elementary school District No. 1 v. state of Montana, 769 P. 2d 584 (1989). Hornbeck v, somerset county Board of Education, 458 A. 2d 758 (M.D. 1983). McDaniel v, Thomas, 285 s.E. 2d 156 (1981).
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Milliken V, Green, 212 N.W.2d 711 (1973). Olsen v, state. or 554 P.2d 239 (1976). Pauley Y, Kelley, 255 S.E. 2d 859 (1979). Richland County v, Campbell, 364 S.E. 2d 470 (S.C. 1988). Robinson Y, Cahill, 287 A.2d 187 (1972). Rose v, The council for Better Education. Inc., 790 s.w.2d 186 (1989). San Antonio Independent school District v, Rodriguez, 411 U.S. 1 (1973). 156 san Antonio Independent school District v, Rodriquez, 337 F. Supp. 280 (1972). Serrano v, Priest, 487 P. 2d 1241 (1971). Thompson Y, Enkelking. 537 P.2d 635 (1975).
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BIOGRAPHICAL SKETCH Jeffrey A. Maiden obtained his bachelor's, master's, and doctoral degrees from the University of Florida. He has taught both in secondary and higher education in the state of Florida 157
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I certify that I have read this study and that in my opinion it conforms to acceptable standards of scholarly presentation and is fully adequate, in scope and quality, as a dissertation for the degree of Doctor of Philosophy. R. Craig Wood, Chair erson Professor of Educational Leadership I certify that I have read this study and that in my opinion it conforms to acceptable standards of scholarly presentation and is fully adequate, in scope and quality, as a dissertation for the degree of o tor of hilosophy. Cochair Associate Profe sor of Educational Leadership I certify that I have read this study and that in my opinion it conforms to acceptable standards of scholarly presentation and is fully adequate, in scope and quality, as a dissertation for the degree of Doctor of Philosophy. Cifm~UJ;/k~ arnes W. Hensel Professor of Educational Leadership I certify that I have read this study and that in my opinion it conforms to acceptable standards of scholarly presentation and is fully adequate, in scope and quality, as a dissertation for the degree of Doctor of Philosophy. M. David Miller Associate Professor of Foundations of Education
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This dissertation was submitted to the Graduate Faculty of the College of Education and to the Graduate School and was accepted as partial fulfillment of the requirements for the degree of Doctor of Philosophy. August, 1994 College of Educat~ Dean, Graduate School
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