While Brown v. Board of Education eliminated de jure segregation in schools in 1954, in 1973 the San Antonio Independent School District v. Rodriguez decision all but guaranteed that de facto segregation would continue.
That decision was about school funding. In Rodriguez, the Supreme Court ruled that a system of relying on local property taxes for supplemental educational revenue was nondiscriminatory, even though it meant that schools in poorer districts without a high property tax base would inevitably receive less funding.
By limiting any federal oversight of states’ school funding systems, the Rodriguez decision maintained a status quo in which states, not the federal government, were responsible for making sure school funding systems meet constitutional standards. This has not been a success: Despite dozens of state-level legal challenges about equitable school funding since the 1973 case, the condition of state school finance in most states remains unfair and inequitable, depriving millions of poor and minority students of the opportunity for school success.
It is well established that a fair funding system progressively distributes resources so that additional funding is targeted to schools with high concentrations of student poverty. Poor students need additional supports — such as early childhood education, tutoring, small class sizes and social workers — to help them achieve state academic standards. High-poverty schools, which are often also heavily minority schools, falter without these essential resources. The glaring inequity between racially segregated, economically disadvantaged schools and their more affluent neighbors intensifies the challenge of eradicating school segregation because wealthier families are unlikely to support or participate in desegregation plans that involve sending their children to under-resourced and under-performing schools. Any viable plans to reduce segregation will require a significant investment to make the long-neglected, segregated schools attractive to new families.
One need only look to Texas, where the Rodriguez case originated, to see how school segregation and school finance interact to severely disadvantage poor students and students of color. In the latest edition of “Is School Funding Fair? A National Report Card” from the Education Law Center, Texas received the unenviable distinction of failing or below-median grades on all four measures of funding fairness: It is a low-funded, low-effort (in terms of education spending relative to economic output) state, where high-poverty districts do not receive the additional resources they require and where wealthier families leave the public school system in large numbers.
Researchers at the University of Texas analyzed school-level data from the Texas Education Agency and found persistently high levels of segregation by race/ethnicity, socioeconomic status and language. The majority of schools experiencing “triple segregation” are rated as low-performing, employ the lowest-skilled teachers and have high teacher and principal turnover. In absence of a funding system that directs greater resources to such struggling schools, it is not surprising that racial and economic achievement gaps on state assessments are persistent and even growing.
While the intense levels of segregation and unfair funding in Texas might be extreme, such disparities are a common condition across the country. The National Report Card shows that disparities in per-pupil funding levels between states are vast, from a low of $5,746 in Idaho, to a high of $17,331 in Alaska. Many of the lowest-funded states allocate a very small percentage of their economic capacity to fund public education. Most states have “flat” or “regressive” school funding systems, where students in districts with concentrated poverty receive the same or even less funding than their wealthy peers. Only a handful of states have comparatively high funding levels that are “progressively” distributed, in other words, where districts with high poverty concentrations receive more funding.
States that rank poorly on funding fairness have limited access to early childhood education, are unable to provide competitive wages for teachers and have higher teacher-to-pupil ratios, depriving students of the educational supports they need to succeed. Unsurprisingly, some of the largest and most segregated metropolitan areas, such as Philadelphia and Chicago, also have the most fiscally disadvantaged public school systems, where higher-than-average poverty levels and lower-than-average resources compared with surrounding areas leave these urban districts severely disadvantaged in their ability to attract and retain teachers and staff.
While equitable funding alone will not remedy the entrenched segregation seen in so many of the nation’s schools, it could begin to improve conditions so that poor and minority students are not inextricably linked to substandard schools. Strategies to reduce segregation, such as inter-district choice programs or regional consolidation, would be far more palatable if state school funding systems were organized to meet the needs of all students. If the goal is to provide all students with the opportunity to succeed in school, then funding and desegregation need to be on the table, together.
Farrie is research director at the Education Law Center and co-author of “Is School Funding Fair? A National Report Card,” an annual report on the condition of states’ school finance systems.