Power in Numbers - Arbitrary Funding

How the Supreme Court Upheld Education Funding Inequity

In this third installment of Power in Numbers, EdBuild finds that similar school districts across the country spend radically different amounts on their students, even when differences in local costs are taken into account, revealing systemic and unjustifiable inequities in the way we fund our schools.

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In the late 1960’s, parents from Edgewood, an urban school district within the city of San Antonio, brought suit against the state and seven school districts, claiming that the Texas system of funding schools was unconstitutional. Their main claim was that the state’s reliance on local property taxes to fund schools favored more affluent communities, giving them more resources for their schools. While they recognized the state’s attempt to partially compensate for the inequalities with state funding, they argued that since low-income districts still ended up with less money, they were substantially disadvantaged, and the system should be struck down as a violation of the United States Constitution’s guarantee of equal protection under the law.

The case, San Antonio v. Rodriguez, made it to the Supreme Court, and in 1973, the Court ruled that Texas' education finance system did not violate the U.S. Constitution. It based its ruling on two tenets—first, that low-income communities are not a protected class, unlike racial or religious minorities, and second, that education is not a fundamental right under the United States Constitution. Without these two protections, as long as a state's funding scheme has a “legitimate” or “rational basis,” the U.S. Supreme Court could not strike it down, even if it clearly disadvantaged struggling communities[1].

With its ruling in San Antonio, the Supreme Court forfeited any responsibility to level the playing field for poor students, and left their fates to 51 state definitions of “equity” and “opportunity”. Today, there are no federal criteria for what constitutes an education, leaving each state to set its own standards and requirements. In some states, education systems must be “thorough and efficient.” In others, they must be “uniform and general.” Still others expect schools to prepare each child to participate in democracy. These different standards create a system in which your home state and community dictate the level of education to which you are entitled.

The map below shows just what that means. It shows the amount by which school funding in every school district in America differs from $11,866, the average per-pupil revenue in all districts in the nation. These numbers are adjusted for local variations in the cost of living, so they are directly comparable across states and across the country. As you can see at a glance, there is huge variation in the resources that each district has available for their students - the poorest districts, in fact, receive 21% less funding than the wealthiest ones do.

School Districts, Difference from National Average

As Justice Marshall predicted in his dissent to the San Antonio v Rodriguez ruling, while school funding systems might discriminate between districts rather than students, "the impact of that discrimination falls directly upon the children whose educational opportunity is dependent upon where they happen to live." To be sure, we at EdBuild believe that there should be differences in the amount of money spent on education in different communities, but this variation should be based on levels of student need, not on the happenstance of location. Education spending today is wildly inconsistent, even between districts serving similar student populations.

In the data presented below, we highlight the 200 largest districts (based on their student enrollment) to reveal large and systemic inequities in the way we fund schools across the country[2]. We have sorted these districts into fourteen peer groups based on their demographics and budget constraints so that it’s easy to compare spending levels in similar districts. Just like the variation among state education budgets, the disparities in the budgets of comparable school districts demonstrates the arbitrariness of education funding in America. As we see again and again in districts around the country, education funding levels are determined by local wealth and state will—not by student need or any legitimate education considerations.

Peer Group 2, for instance, consists of eight school districts, all middle-income with more than 50,000 students and very high rates of students who qualify for free or reduced-price lunch under the National School Lunch program. They educate some of the highest-need students in the country, and yet all have revenues well below the national average of $11,886. Even at a mere $8,141 per pupil after cost-adjustment, Clayton County Schools, located just outside of Atlanta, receive the second-highest funding in this peer group[3]. Granite School District in Salt Lake City brings up the rear with $5,652 per pupil after cost-adjustment, almost $2,500 less than Clayton County and over $6,000 less per pupil than the national average. After cost-adjustment, it's clear how arbitrary any individual district’s revenue really is. Click the SELECT A PEER GROUP button in the map below to view all of 200 largest districts or to select another group to compare. The table underneath the map shows each of the districts, their per-pupil spending, and the different student need factors that affect their costs.

Largest 200 School Districts

Name Revenue Per Pupil Median Household Income % FRL % ELL % SPED Peer Group
Baltimore City SD, MD $11,717 $33,811 84% 4% 17% 1
Philadelphia SD, PA $11,915 $27,652 80% 8% 17% 1
Fresno Unified SD, CA $6,678 $28,979 89% 24% 10% 1
San Bernardino City Unif SD, CA $6,746 $31,882 91% 27% 10% 1
Aldine Ind SD 902, TX $7,075 $32,034 85% 25% 7% 1
San Antonio Ind SD 907, TX $7,875 $30,481 93% 16% 10% 1
Milwaukee City SD, WI $11,397 $32,344 82% 10% 20% 1
Clayton County SD, GA $8,141 $41,519 86% 7% 10% 2
Memphis City SD, TN $8,414 $36,082 82% 6% 12% 2
Santa Ana Unified SD, CA $5,664 $38,653 84% 50% 11% 2
Houston Ind SD 912, TX $7,330 $40,373 80% 26% 8% 2
Pasadena Ind SD 917, TX $7,184 $38,694 79% 24% 9% 2
Fort Worth Ind SD 905, TX $8,129 $39,008 77% 28% 8% 2
Dallas Ind SD 905, TX $7,897 $38,206 89% 36% 7% 2
Granite SD, UT $5,652 $50,040 78% 15% 12% 2
Clark County SD, NV $7,944 $49,599 55% 17% 11% 3
Dekalb County SD, GA $9,217 $45,691 71% 11% 9% 3
Omaha City SD 1, NE $9,509 $42,657 73% 12% 17% 3
Mesa Unified SD, AZ $6,770 $41,813 57% 6% 12% 3
Tucson Unified SD 1, AZ $7,747 $38,622 65% 6% 15% 3
Cumberland County SD, NC $6,243 $41,912 58% 2% 14% 3
Forsyth Co Winston Salem SD, NC $7,533 $44,479 54% 11% 12% 3
Guilford County SD, NC $7,580 $43,684 57% 8% 14% 3
Charlotte Mecklenburg SD, NC $6,971 $51,053 55% 10% 9% 3
Columbus City SD, OH $15,302 $36,104 73% 11% 17% 3
Albuquerque SD, NM $8,443 $45,874 65% 17% 15% 3
Wichita Unified SD 259, KS $9,965 $40,893 74% 16% 13% 3
Knox County SD, TN $8,039 $48,717 47% 3% 12% 3
Nashville Davidson County SD, TN $9,419 $45,779 71% 11% 12% 3
Jefferson County SD, KY $10,168 $45,013 59% 6% 13% 3
Elk Grove Unified SD, CA $6,159 $50,582 55% 17% 10% 3
Long Beach Uni SD, CA $5,723 $38,347 62% 21% 11% 3
San Diego City Unified SD, CA $7,084 $44,696 65% 23% 11% 3
San Francisco Unified SD, CA $6,582 $43,153 57% 25% 12% 3
Mobile County SD, AL $8,141 $44,650 73% NA 12% 3
Greenville County SD, SC $8,795 $46,570 49% 11% 13% 3
El Paso Ind SD 902, TX $8,069 $41,911 69% 20% 9% 3
Arlington Ind School, TX $7,415 $48,125 68% 18% 8% 3
Austin Ind SD 901, TX $10,380 $51,615 63% 25% 10% 3
Denver SD 1, CO $9,247 $41,684 71% 32% 0% 3
Broward County SD, FL $7,133 $47,323 57% 10% 12% 3
Miami Dade County SD, FL $7,251 $40,280 73% 20% 10% 3
Duval County SD, FL $7,160 $45,934 49% 3% 14% 3
Hillsborough County SD, FL $7,366 $47,100 57% 12% 14% 3
Lee County SD, FL $7,765 $45,440 65% 7% 13% 3
Orange County SD, FL $8,694 $45,576 62% 14% 11% 3
Osceola County SD, FL $8,092 $46,993 72% 17% 11% 3
Palm Beach County SD, FL $7,843 $46,441 55% 11% 15% 3
Pasco County SD, FL $8,085 $44,967 55% 4% 15% 3
Pinellas County SD, FL $6,976 $40,693 54% 5% 12% 3
Polk County SD, FL $8,314 $43,505 67% 10% 11% 3
Volusia County SD, FL $7,988 $42,756 58% 5% 16% 3
Washoe County SD, NV $7,690 $49,709 45% 16% 13% 4
Brevard County SD, FL $7,272 $46,640 45% 3% 16% 4
Newark City Public SD, NJ $22,942 $26,326 83% 10% 17% 5
Detroit Public SD, MI $11,950 $24,923 79% 11% 17% 5
Cleveland City SD, OH $17,769 $24,654 NA 7% 22% 5
Oklahoma City SD 89, OK $8,486 $33,366 86% 30% 12% 5
Twin Rivers Unified SD, CA $7,065 $31,540 76% 28% 11% 5
Stockton City Unified SD, CA $6,842 $30,574 86% 29% 9% 5
Alief Ind SD 903, TX $7,362 $33,103 82% 31% 8% 5
Brownsville Ind SD 901, TX $8,756 $34,596 96% 29% 10% 5
Cincinnati City SD, OH $15,978 $33,827 64% 4% 21% 6
St Louis City SD, MO $9,064 $31,668 68% 5% 13% 6
Boston City SD, MA $14,250 $34,141 72% 28% 20% 6
Atlanta Public SD, GA $12,149 $40,869 75% 3% 9% 7
Richmond County SD, GA $8,437 $37,561 78% 1% 8% 7
Tulsa SD 1, OK $7,881 $36,103 83% 17% 15% 7
Fontana UnifiedSD, CA $6,771 $43,655 87% 37% 12% 7
Moreno Valley Unified SD, CA $6,428 $44,270 81% 24% 12% 7
Oakland Unified SD, CA $7,199 $38,907 77% 31% 11% 7
Ysleta Ind SD, TX $8,447 $37,290 81% 21% 10% 7
Pharr San Juan Alamo Ind SD 909, TX $9,260 $39,161 89% 40% 6% 7
Irving Ind SD 912, TX $7,683 $40,150 81% 36% 8% 7
Edinburg Ind SD 904, TX $8,984 $43,324 85% 29% 7% 7
East Baton Rouge SD, LA $11,094 $44,872 80% 4% 10% 7
Jefferson Parish SD, LA $9,670 $45,615 75% 9% 11% 7
Chatham County SD, GA $9,136 $42,718 65% 2% 10% 8
Muscogee County SD, GA $9,008 $38,185 67% 2% 12% 8
Durham County SD, NC $8,735 $49,290 64% 14% 14% 8
Gaston County SD, NC $6,662 $42,017 60% 5% 12% 8
Norfolk City SD, VA $8,441 $39,634 64% 2% 14% 8
Hamilton County SD, TN $8,094 $47,510 58% 3% 12% 8
Fayette County SD, KY $10,546 $48,788 47% 9% 10% 8
Salem Keizer SD 24J, OR $8,182 $42,393 58% 16% 16% 8
Garden Grove Unif SD, CA $5,645 $41,677 71% 42% 11% 8
Riverside Unified SD, CA $6,545 $49,077 64% 17% 11% 8
Sacramento City Unified SD, CA $6,544 $36,679 72% 24% 12% 8
Jefferson County SD, AL $7,799 $51,138 56% NA 13% 8
Montgomery County SD, AL $7,547 $45,397 72% NA 10% 8
Charleston County SD, SC $13,369 $47,692 52% 6% 10% 8
Horry County SD, SC $11,444 $43,165 63% 7% 15% 8
Spring Ind SD 919, TX $7,445 $46,240 73% 17% 8% 8
Killeen Ind SD 906, TX $6,619 $47,457 56% 7% 11% 8
Corpus Christi SD 904, TX $7,803 $45,365 69% 4% 10% 8
Mesquite Ind SD 914, TX $7,302 $44,617 70% 16% 10% 8
Richardson Ind SD 916, TX $7,649 $48,947 58% 17% 11% 8
Amarillo Ind SD, TX $7,858 $46,002 67% 13% 9% 8
Minneapolis Special SD 1, MN $13,758 $44,382 65% 23% 20% 8
St Paul Ind SD 625, MN $13,061 $42,659 72% 23% 18% 8
Caddo Parish SD, LA $9,815 $40,486 63% 1% 10% 8
Calcasieu Parish SD, LA $9,702 $43,938 58% 1% 15% 8
Adams Arapahoe SD 28J, CO $7,998 $40,924 68% 35% 0% 8
Des Moines Ind Community SD, IA $9,951 $43,783 69% 16% 17% 8
Collier County SD, FL $8,899 $50,128 61% 13% 13% 8
Escambia County SD, FL $7,457 $43,440 61% 1% 15% 8
Lake County SD, FL $7,440 $46,428 57% 4% 12% 8
Manatee County SD, FL $7,661 $46,572 55% 9% 16% 8
Marion County SD, FL $7,496 $40,258 67% 5% 15% 8
Sarasota County SD, FL $9,362 $44,072 52% 6% 14% 8
St Lucie County SD, FL $8,265 $44,895 61% 7% 12% 8
Lincoln Public SD 1, NE $9,947 $49,456 43% 6% 15% 9
Johnston County SD, NC $7,176 $50,213 44% 9% 14% 9
Portland SD 1J, OR $8,585 $46,861 41% 8% 16% 9
San Juan Unified SD, CA $6,336 $41,844 42% 10% 12% 9
Leon County SD, FL $8,165 $45,729 44% 2% 16% 9
DeSoto County SD, MS $7,527 $62,841 52% 4% 14% 10
Prince Georges County SD, MD $14,332 $67,052 59% 13% 12% 10
Gwinnett County SD, GA $8,404 $58,114 56% 11% 11% 10
Henry County SD, GA $8,903 $60,842 52% 1% 13% 10
SD U 46 Elgin Area, IL $11,347 $68,430 61% 24% 13% 10
United Ind SD 903, TX $9,006 $56,044 74% 39% 8% 10
Cypress Fairbanks Ind SD 907, TX $7,230 $63,278 50% 12% 7% 10
Spring Branch Ind SD 920, TX $7,945 $53,515 58% 29% 8% 10
Northside Ind SD 915, TX $8,183 $58,080 53% 6% 11% 10
Socorro Ind SD 909, TX $7,743 $52,547 72% 18% 8% 10
Garland Ind SD 909, TX $7,145 $52,294 61% 19% 9% 10
St Tammany Parish SD, LA $10,752 $58,857 47% 1% 17% 10
Canyons SD, UT $7,172 $65,083 52% 4% 11% 10
Baltimore County SD, MD $11,864 $58,630 46% 4% 13% 11
Cobb County SDrict, GA $8,280 $59,474 45% 8% 12% 11
Fulton County SD, GA $9,460 $58,516 45% 6% 10% 11
Seattle SD 1, WA $10,702 $54,382 40% 9% 13% 11
Wake County SD, NC $6,889 $62,211 35% 8% 13% 11
Chesterfield County SD, VA $8,756 $68,008 22% 5% 12% 11
Henrico County SD, VA $9,353 $56,214 35% 5% 12% 11
Virginia Beach City SD, VA $8,877 $58,650 32% 1% 12% 11
Capistrano Unified SD, CA $5,151 $68,980 24% 10% 9% 11
Corona Norco Unified SD, CA $6,540 $69,224 44% 14% 11% 11
Conroe Ind SD 902, TX $7,733 $67,503 36% 10% 7% 11
North East Ind SD 910, TX $8,636 $56,797 46% 7% 9% 11
Alpine SD, UT $6,142 $69,722 38% 3% 12% 11
Davis Co SD, UT $6,296 $66,324 42% 2% 12% 11
Jordan SD, UT $5,890 $69,628 45% 3% 12% 11
Cherry Creek SD 5, CO $8,801 $63,110 25% 8% 0% 11
Jefferson Co SD R 1, CO $8,305 $62,494 34% 6% 0% 11
Seminole County SD, FL $6,835 $54,624 45% 4% 12% 11
Harford County SD, MD $12,535 $73,359 28% 1% 14% 12
Cherokee County SD, GA $9,241 $66,267 32% 4% 11% 12
Chandler Unified SD 80, AZ $6,203 $66,696 29% 3% 12% 12
Gilbert SD 41, AZ $6,543 $68,177 NA 1% 12% 12
Paradise Valley SD 69 and 217, AZ $7,363 $56,990 NA 5% 13% 12
Peoria Unified SD 11, AZ $6,048 $53,309 40% 2% 14% 12
Deer Valley SD 97, AZ $6,776 $66,034 20% 2% 9% 12
Union County SD, NC $7,262 $65,434 35% 5% 10% 12
Chesapeake City SD, VA $10,119 $65,857 32% 2% 17% 12
Anchorage SD, AK $10,445 $57,888 41% 12% 14% 12
Rutherford County SD, TN $7,853 $63,926 42% 4% 10% 12
Beaverton SD 48J, OR $7,724 $55,987 36% 13% 14% 12
Clovis Unified SD, CA $7,361 $59,143 38% 7% 8% 12
Mt Diablo Unified SD, CA $6,861 $54,113 45% 23% 11% 12
San Jose City Unified SD, CA $7,269 $59,099 44% 25% 10% 12
Meridian SD 2, ID $5,710 $60,396 31% 5% 9% 12
Klein Ind SD 915, TX $7,348 $69,269 41% 11% 8% 12
Humble Ind SD 913, TX $7,896 $74,179 34% 7% 8% 12
Anoka Hennepin SD 11, MN $11,437 $72,447 32% 6% 14% 12
Northglenn Thornton SD 12, CO $8,670 $64,011 37% 12% 0% 12
Clay County SD, FL $7,568 $60,204 36% 2% 18% 12
St Johns County SD, FL $7,766 $61,089 23% 1% 14% 12
Anne Arundel Co Schs, MD $11,655 $76,026 30% 4% 10% 13
Frederick County SD, MD $13,156 $77,945 25% 4% 11% 13
Howard County SD, MD $14,453 $93,982 17% 4% 9% 13
Montgomery County SD, MD $14,480 $81,242 33% 14% 12% 13
Forsyth County SD, GA $8,555 $83,320 19% 4% 12% 13
Fairfax County SD, VA $10,973 $90,034 26% 20% 14% 13
Loudoun County SD, VA $13,074 $108,753 17% 8% 11% 13
Prince William County SD, VA $10,397 $90,179 38% 16% 11% 13
Shelby County SD, TN $7,444 $75,803 37% 2% 11% 13
Williamson County SD, TN $7,594 $94,898 12% 1% 9% 13
Fremont Unif SD, CA $6,337 $75,155 22% 17% 10% 13
Poway Unified SD, CA $7,368 $76,490 14% 12% 11% 13
Keller Ind SD 907, TX $8,565 $85,834 22% 5% 8% 13
Clear Creek Ind SD 910, TX $8,344 $80,532 28% 7% 10% 13
Frisco Ind SD 905, TX $9,439 $98,327 12% 4% 9% 13
Fort Bend Ind SD 907, TX $7,948 $78,375 39% 13% 6% 13
Katy Ind SD 914, TX $8,751 $85,846 30% 11% 8% 13
Plano Ind SD 910, TX $9,838 $76,915 27% 10% 10% 13
Round Rock Ind SD 909, TX $9,272 $75,811 30% 7% 8% 13
Mansfield Ind SD 908, TX $8,140 $78,826 39% 9% 9% 13
Lewisville Ind SD 902, TX $9,353 $82,926 30% 13% 10% 13
Leander Ind SD 913, TX $9,659 $84,256 22% 4% 9% 13
Douglas Co SD Re 1, CO $7,674 $86,142 11% 3% 0% 13
Chicago City SD 299, IL $9,266 $37,847 85% 16% 12% 14
New York City SD, NY $11,801 $28,172 66% 0% 19% 14
Los Angeles Unified SD, CA $7,443 $33,897 59% 28% 13% 14

State constitutions guarantee most American children the right to an education—but not necessarily the best education. For a child in Virginia, the state must provide a “high quality” school system to satisfy its obligation, while in Georgia, a child’s educational rights are met by a merely “adequate” education. And on top of its constitutional obligations, each state faces its own economic conditions, and has a limited pot of public funds. The combination of all three of these factors produces a hodgepodge of school systems, funded at levels that are inconsistent from one to the next and that bear little relationship to student need. The San Antonio ruling means that, even though the federal government provides approximately 9% of total education revenue, it has little role in addressing the inconsistencies and inequities in education funding.

As a country, we recognize that states are different and respect certain areas of traditional state control, but we know that some issues—especially ones that relate to our health and welfare—are truly national concerns. Air and water don’t stop at the border, so we rely on the federal Environmental Protection Agency, not state legislatures, to set limits on the pollutants we can emit into the air and the contaminants we allow. Contaminated food makes Floridians just as sick as Oregonians, so we ask the Food and Drug Administration, not each state, to ensure that our food supply is safe. Even in the realm of education, the federal government sets national standards for the education of students with disabilities to ensure that each state serves those children well. But all children grow, develop, and learn in essentially the same way from state to state, and instead of setting any national expectations, we have delegated education funding policy to the states, with the result that a single student might receive radically different levels of resources and support in one state than another, and indeed, in one district than another.

These disparities exist for no other reason than that we lack any uniform notion of what it means to properly support our children. After adjusting for variations in costs and finding that large inequities remain, we are left with no choice but to conclude that our system funds students’ education by luck and by lot rather than by logic.