Bradley, A. (1994), Equation for equality. Education Week, 14(2) September.
California Budget Project (July 1996). How the Budget was Balanced: Tax Increases for Renters, Tax Cuts for Corporations, Welfare Cuts Continued. Vol. 2:4. Sacramento.
California Education Code Section 14600.
California Education Code Section 14700, et seq.
California Education Code ¤ 41060.
California Education Code ¤ 41200.
California Department of Education, Fact Book, Part III, 1992-93.
California Government Code Section 8880, et seq.
California State Constitution, Article XIII B, Section 1, et seq.
California State Constitution, Article XVI, Section 8, et seq.
Carroll, S.J. and Park, R.E. (1983), The search for equity in school finance, Ballinger Publishing Company, Cambridge, Massachusetts
Catterall, J. and Thresher, T. (1979) Proposition 13: The campaign, the vote, and the immediate aftereffects for California schools. Program Report 79-B5 Institute for Research on Educational Finance and Governance, Stanford University.
Catterall, J. S. and Brizendine, E. (1985), Proposition 13: Effects on high school curricula, 1978 - 1983, American Journal of Education.
Chanda Smith v. LAUSD, (1995) Case No. CV 93-7044-LEW.
Crawford v. Board of Education of the City of Los Angeles, (1976) 17 Cal. 3d. 280.
Due, John, Alternative tax sources for education, Ch. 5 p. 126 (1972) Johns, R.L., Alexander K., Jordan K.F. (eds.), Financing education, fiscal and legal alternatives, Charles E. Merrill Publishing Company, Columbus Ohio.
Eastin, Delaine, Memorandum to California Departments Concerning Governor's Budget for FY 1995-96, p.1 (January 30, 1995).
EdSource (1990). Categorical Aid for California Schools. Menlo Park, CA: EdSource.
EdSource (1994). EdSource Report: School Finance 1994-95. Menlo Park, CA: EdSource.
EdSource (1995). Selected Readings on California School Finance. Menlo Park, CA: EdSource.
EdSource (1995). EdSource Report: School Finance 1995-96. Menlo Park, CA: EdSource.
EdSource (1995). EdSource Report: Special Education -- The Other School Finance System. Menlo Park, CA: EdSource.
Goldfinger, Paul M., Revenues and Limits: A Guide to School Finance in California. School Services of California, Inc. (1996)
Kirp, M., Yudof, M., and Levin, B. (1993 3d ed.). Education Policy and the Law. West.
Kuttner, R. (1980). Revolt of the Haves: Tax Rebellions and Hard Times. Simon and Schuster: New York.
Los Angeles Unified School District, Budget Services and Financial Planning Division, Adjusted Final Budget (1994).
Los Angeles Unified School District, Budget Services and Financial Planning Division, Special Committee of the Whole, Preliminary Analysis of Governor's 1995/6 Budget (1995).
Picus, Lawrence O., California School Finance 1996: Still Driving a Chevrolet but threatened by the imports. AERA (1996).
Picus, Lawrence O., Cadillacs or Chevrolets?: The Evolution of State Control Over School Finance in California 17 Journal of Education Finance 33 (1991).
Pyle, A., L.A. Schools Wrestle With Realities of '92 Money Pact, Los Angeles Times (February 14, 1995).
Reutter, Jr., E. Edmund and Hamilton, Robert R., The Law of Public Education (2d ed. 1976).
Rodriguez v. Los Angeles Unified School District, Case No. C 611 358, Statement of Decision, Los Angeles Superior Court (1992).
Rodriguez v. Los Angeles Unified School District, Case No. C 611 358, Consent Decree, Los Angeles Superior Court (1992).
Serrano v. Priest (Serrano I) (1971) 5 Cal. 3d 584, 96 Cal. Rptr. 601, 487 P.2d 1241.
Serrano v. Priest (Serrano II (1976)) 18 Cal. 3d 728, 135 Cal. Rptr. 345, 557 P.2d 929.
Serrano v. Priest (Serrano III (1986)) 200 Cal. App. 3d 897, 226 Cal. Rptr. 584.
Taylor, J.M. (1981). Courts, Dollars and Schools: The California School Finance Litigation and its Aftermath. The University of Arizona.
Theobald, Neil D., Picus, Lawrence O., Living with Equal Amounts of Less: Experiences of States with Primarily State-Funded School Systems, Journal of Education Finance 17 (summer, 1991).
2 Property taxes are levied locally even though they are a state tax. Reutter, E.E. & Hamilton, Robert R. (1976). The Law of Public Education. p. 179. Property taxes for revenue limits are allowed under Proposition 13 limitations and are distributed to cities, counties, school districts and other agencies in accordance with formulas adopted by the State Legislature. The amounts received by school districts provide a portion of the District's Revenue Limit. Los Angeles Unified School District (1994). Adjusted Final Budget 1994-1995. p. xv.
3 For example, the Court in Serrano v. Priest, 96 Cal. Rptr. 601 (1971) (Serrano I) found that "in Los Angeles County, the Baldwin Park Unified School District expended only $577.49 to educate each of its pupils in 1968 1969; during the same year the Pasadena Unified School District spent $840.19 on every student; and the Beverly Hills Unified School District paid out $1,231.72 per child. Id. at 608.
4 Supra note 3.
5 Serrano I (1971), at 613.
6 Stats. 1972, ch. 1406 and Stats 1973, ch. 208 respectively.
7 The trial court found that SB 90 would "allow total 'convergence' between high spending revenue limits and rising foundation levels only after many, perhaps as many as 20, years Even assuming no voted overrides. After five years of functioning again assuming that no voted overrides occur, many high-wealth, high spending districts will still be spending two to three times more per pupil than many low-wealth districts are able to spend. Even when the 'convergence' has run its course, there will continue to be a substantial inequality between basic-aid and equalization-aid districts, again assuming no voted overrides, due to the fact that the former districts will be able to achieve the foundation level at a tax rate which is less than the computational rate." Serrano v. Priest, 135 Cal. Rptr. 345 (1976), 353 (Serrano II (1976)).
8 The foundation grant or scheme has been the second most common formula for equalizing school funding used by the states. First introduced in the early 1920s, the formula attempts to reconcile the right of local districts to support and govern their own schools with the obligation of the state to lessen the disparity of educational provisions among districts. The theory is that any school district, even property poor districts, should be assured certain minimum levels of revenue per pupil, provided the district makes its own effort to raise funding by imposing stipulated minimum property taxes. The amount the district will pay is computed in accordance with a legislatively determined tax rate and the state provides the difference between the amount contributed from local revenues at that tax rate and the state-guaranteed minimum. Districts with low property bases will raise only limited revenue at the specified tax rate and the state will make up the difference. Property rich districts may raise more than the state-guaranteed minimum at the specified tax rate and thus will receive no "equalization aid" from the state. In theory, this program creates something close to revenue equality. In practice, however, the program is frequently not strictly followed, causing inequalities between school districts. James B., Hoffman, J. (1993). Brown in State Hands: State Policymaking and Educational Equality After Freeman v. Pitts. Hastings Constitutional Law Quarterly: Vol. 20: 3. 521-577. p. 565-566 and Yudof, M. Kirp, D., and Levin, B. (1993 3d ed.). Education Policy and the Law. West.
9 Taylor, J.M. (1981). Courts, Dollars and Schools: The California School Finance Litigation and its Aftermath. The University of Arizona.
10 Serrano v. Priest, Judgment, August 30, 1974, at paragraph 3(c) cited in Goldfinger, P.M. (1996). Revenues and Limits: A Guide to School Finance in California. School Services of California Inc.
11 A flat grant is a system in which funds are distributed on the basis of equal dollars per pupil to each school district regardless of whether the district is property rich or property poor. The flat grant assumes that a specific basic or minimum level of education should be guaranteed to every student. Thus, the state distributes this minimum level of dollars per pupil to every school district. Any additional amount spent on education is a matter for each individual school district to decide but will not be subsidized by the state. One of the difficulties with this method is that the flat grant is not based on any particular level of education that the dollar buys, nor does it take into account pupils with special, more costly needs, or differences in the cost of providing the same educational services in rural, urban & suburban school districts. Kirp, et al. supra, note 8.
12 Serrano v. Priest, (1986) 226 Cal. Rptr. 584, 592 (Serrano III (1986)).
13 Id. at 593.
14 The comparison between Beverly Hills and Baldwin Park is probably the most commonly drawn comparison. It is liekly that this comparison is used because it is the one cited by the Court in Serrano I, II, and III. The Court used Beverly Hills School District and Baldwin Park School District to demonstrate the discrepancies in Los Angeles County:
Serrano I (1971) 96 Cal. Rptr. at 608.
15 Id. at 614.
16 Serrano III (1986) at 616. ADA stands for average daily attendance. According to Goldfinger, "[t]here are several kinds of attendance, and these are counted in different ways. For regular attendance, ADA is equal to the average number of pupils actually attending classes who are enrolled for at least the minimum school day, or have a valid excuse." ADA is also used in the context of adult education and ROC/P. Attendance is counted every day of the school year and is reported to the California Department of Education three times a year. Goldfinger, supra note 10 at 215.
17 Serrano III (1986) at 620.
18 Some commentators have speculated that the Serrano cases contributed to the strong tax payer support for reducing property tax rates.
19 The text of Proposition 13 reads as follows:
Section 1. (a) The maximum amount of any ad valorem tax on real property shall not exceed one percent (1%) of the full cash value of such property. The one percent (1%) tax to be collected by the counties and apportioned according to law to the districts within the counties.
(b) The limitation provided for in subdivision (a) shall not apply to ad valorem taxes or special assessments to pay the interest and redemption charges on any indebtedness approved by the voters prior to the time this section becomes effective.
Section 2. (a) The full cash value means the County Assessors valuation of real property as shown on the 1975-76 tax bill under "full cash value", or thereafter, the appraised value of real property when purchased, newly constructed, or a change in ownership has occurred after the 1975 assessment. All real property not already assessed up to the 1975-76 tax levels may be reassessed to reflect that valuation.
(b) The fair market value base may reflect from year to year the inflationary rate not to exceed two percent (2%) for any given year or reduction as shown in the consumer price index or comparable data for the area under taxing jurisdiction.
Section 3. From and after the effective date of this article, any changes in state taxes enacted for the purpose of increasing revenues collected pursuant thereto whether by increased rates or changes in methods of computation must be imposed by an Act passed by not less than two-thirds of all members elected to each of two houses of the Legislature, except that no new ad valorem taxes on real property, or sales or transaction taxes on the sales of real property may be imposed.
Section 4. Cities, counties and special districts, by a two-thirds vote of the qualified electors of such district, may impose special taxes on such district, except ad valorem taxes on real property or a transaction tax or sales tax on the sale of real property within such city, county or special district.
Section 5. This article shall take effect for the tax year beginning on July 1 following the passage of this amendment, except Section 3 which shall become effective upon the passage of this article.
Section 6. If this section, part, clause, or phrase hereof is for nay reason held to be invalid or unconstitutional, the remaining sections shall not be affected but will remain in full force and effect.
Catterall, J. and Thresher, T. (1979) Proposition 13: The campaign, the vote, and the immediate aftereffects for California schools. Program Report 79-B5 Institute for Research on Educational Finance and Governance, Stanford University.
20 When Jerry Brown became Governor in 1975 the state surplus had grown to three quarters of a billion dollars. Had Proposition 13 not passed it is highly likely that this surplus would have continued to grow. At the time that Proposition 13 passed, the state surplus immediately dropped to $4 billion. Kuttner, R. (1980). Revolt of the Haves: Tax Rebellions and Hard Times. Simon and Schuster: New York.
21 For a more complete analysis of the impact of Proposition 13, on curriculum, see Catterall, J.S. and Brizendine, E. (1984). Proposition 13: Effects on High School Curricula, 1978-1983. University of Chicago.
22 Id. at 342.
23 Id.
24 Goldfinger, supra note 10 at 6.
25 Id.
26 Los Angeles Unified School District, Budget Services and Financial Planning Division, Special Committee of the Whole, Preliminary Analysis of Governor's Proposed Budget For 1995-96 And Its Financial Implications For The L.A.U.S.D., p. 3 (1995).
27 Goldfinger, supra note 10 at 16.
28 Los Angeles Unified School District (1995), Budget Services and Financial Planning Division, Special Committee of the Whole, Preliminary Analysis of Governor's Proposed Budget for 1994-95 and its Financial Implications for the LAUSD., p. 3.
29 Picus, L.O. (1996). California school finance 1996: Still driving a Chevrolet but threatened by the imports. AERA. In 1994-95, Lottery income added 1.9% to school district revenues. EdSource (1996).
30 C.A. Const. Art. XVI, ¤8. (emphasis added). Section 8 was added to the Constitution in 1974.
31 Section 8.5 provides for the allocation of funds to the state school fund.
32 In 1980 this section was subject to Section 3 of Stats.1980, c. 1205, which provides: "The Legislature finds and declares that Article XIIIB of the California Constitution is intended to provide certain limitations and controls on government spending at all levels of government in the state, but these restrictions are intended to be applied in a reasonable and practical way so as to permit flexibility in meeting the constantly changing conditions and needs of the people for governmental services. . . By way of example, the California Constitution requires that the legislature provide for a system of public schools and the courts of this state have held that a method of financing this public school system which depends substantially on local property taxes with resultant wide disparities in school revenue violates constitutional provisions guaranteeing equal protection of the laws. If Article XIII B were construed to require that all money expended by a local school district was required to be included within its appropriations subject to limitation, attempts to accommodate each of these separate demands of the California Constitution could be substantially frustrated."
33 C.A. Const. Art. XIII, ¤1.
34 Proposition 4 became Article XIIIB, added to the Constitution after it was approved by the people at a special statewide election held November 6, 1979. CA Constitution Art. XIIIB.
35 Goldfinger, supra note 10 at 12.
36 As a result, the population growth factor is now based 40% on the growth in public school enrollment and 60% on the growth in the state's population. The 40% figure was derived by using the portion of the state's general fund budget guaranteed to schools by Proposition 98. Picus, supra, note 29 at 51.
37 Goldfinger, supra note 10 at 13.
38 This Proposition was codified as Education Code ¤ 41060.
39 CAL. Education Code ¤41200 (West, 1995).
40 It has become a maximum funding level not to be exceeded because of spending limitations. Picus states: "One of the unintended consequences of Proposition 98's funding guarantees is that the legislature has treated it as both a floor and a ceiling. Consequently, legislators have been unwilling to give the schools any more money than require by Proposition 98. To ensure that the schools don't receive additional funds, the legislature establishes an annual Proposition 98 reserve fund. If state revenues decline the state won't be committed to distribute funds to the schools beyond the minimum guarantee, and the money in the reserve fund can be used for other purposes. This factor alone should work to suppress available funding for education n the future...This measure guaranteed school districts 40 percent of the state's general fund budget. Although educational interest groups thought this measure would solve the schools financial difficulties, the legislature treated this requirement not only as a spending floor, but also as a ceiling, deciding that the remaining 60 percent of the general fund would go to all other services." Picus, supra, note 29 at 56, 58.
41 Goldfinger supra note 10 at 23.
42 Id. at 24-25.
43 If one reads the language of the actual text of Proposition 98 it is difficult not to find the present circumstances ironic. Proposition 98 stated, in pertinent part:
44 "Sec. 61. (a)(1) The appropriations of emergency loans made in Sections . . . shall be considered as, and is hereby deemed to be, one loan to be repaid from amounts appropriated for the purpose of meeting the minimum funding requirements for school districts. . . imposed by Section 8 of Article XVI of the California Constitution." 61 Stats. 1993, c. 66 (S.B.399).
45 Although less than the statutory COLA of 3.35 percent, for the first time in the last several years the Governor's 1995-96 budget offered a COLA of 2.21% for the revenue limit ADA. Los Angeles Unified School District, Budget Services and Financial Planning Division, supra note 9, p.1 (1995). The actual cola was 2.73 percent, the first fully funded COLA in the 1990s. Goldfinger, supra note 10.
46 Picus, supra note 29 at 48.
47 Goldfinger, supra note 10 at 30.
48 Government Code Section 8880.
49 CAL. Government Code ¤8880.4 (West, 1995).
50 CAL. Government Code ¤ 8880.4 (West, 1995).
51 According to Picus the Lottery has provided up to 4% of K-12 revenues. He further suggests that its impact on education at times has been considerable. Picus, supra, note 29, at 49. This perception is obviously different than the one conveyed in the California Department of Education Fact Book of 1992-93.
52 California Department of Education, Fact Book, Part III, 1992-93, p. 8.
53 Los Angeles Unified School District, Budget Services and Financial Planning Division, Adjusted Final Budget, p. 2 (1994).
54 Although schools are not supposed to rely on Lottery funds to support basic education programs, because of budget cutbacks, many schools have become dependent on these resources to provide regular programming.
55 The specific details of the federal and state funding model will not be presented within the body of this paper due to the lack of space and the complexity of the system. Rather, this section is intended to introduce readers to the special education funding mechanism and raise questions and concerns that must be addressed in the context of a reorganization of LAUSD. For a comprehensive analysis of special education funding, see Goldfinger, supra note ___. This guide includes worksheets and tips on education funding and is put out yearly. Additionally, this section is not intended to provide an overview of the federal and state special education programs. The purpose of this section is to present an overview of the funding mechanisms involved in providing special education for students in LAUSD. For an analysis of the impact of the Hayden Bill on the federal and state laws governing the delivery of special education, please see the Special Education Briefing Paper in this document.
56 EdSource (1995) Report: Special Education - The Other School Finance System. EdSource, Inc. Menlo Park, California. [hereinafter Special Education Report] Average excess cost is defined as the average amount needed to provide an appropriate education to a student with disabilities that exceeds the expenditure for a regular student. Id. at 3.
57 Id.
58 Id. at 4.
59 Picus, supra note 29.
60 Special Education Report, supra note 56 at 4.
61 Goldfinger, supra note 10.
62 Id.
63 The encroachment represents the amount of money required from the District's general fund to fully finance the costs of special education operations and programs. The larger the encroachment, the more special education "costs" the district. Consultant's Report, Chanda Smith v. LAUSD, Consultant's Report, October 1995. [hereinafter Consultant's Report]. Louis Barber, Ph.D., Mary Margaret Kerr, Ed.D at 149.
64 Special education ADA includes only those pupils who attend Special Day Classes in either Special Education Schools or in regular schools. It does not include ADA for pupils in regular classes who receive special education services on a part-time basis. Los Angeles Unified School District, Adjusted Final Budget, 1994-95 [hereinafter LAUSD Adjusted Budget], p. A-16.
65 Case No. CV 93-7044-LEW (1995).
66 Id. at 150.
67 Goldfinger, supra note 10.
68 Id.
69 Consultant's Report, supra note 63 at 148. Unless otherwise stated, information relating specifically to LAUSD and special education is based on information obtained from the Consultant's Report which in turn is based on numbers provided by LAUSD Budget Services Branch, the Special Education division's Principal Financial Analyst and the J-50 and J-380 forms filed by the District with the California State Department of Education. Id. at 149, fn. 40.
70 Id. The $39 million is commonly known as the Local General Fund Contribution (LGFC) and is one portion of the "encroachment" of special education into the general fund. Id. at 149.
71 Reproduced from the Consultant's Report, supra note 63 at 153.
72 This category includes funding for students placed with non-public agencies.
73 Picus, supra note 29.
74 EdSource (1995). EdSource Report: School Finance 1995-96. Menlo Park. [hereinafter School Finance Report I].
75 EdSource (October 1994). EdSource Report: School Finance 1994-95. Menlo Park, p. 4. [hereinafter School FinanceReport II].
76 LAUSD Adjusted Budget, supra note 64 at xiv.
77 In 1994-95 federal funds accounted for 4.2% of the Child nutrition Program, 6.5% of the Specially Funded Programs, 5.5% of Disaster Relief monies, and 0.7% of all other federal revenue. Id. at xvii.
78 EdSource (1990). Categorical Aid for California Schools. Menlo Park. [hereinafter Categorical Aid].
79 School Finance Report I, supra note 74.
80 School Finance Report II, supra note 75.
81 School Finance Report I, supra note 74.
82 Id.
83 Goldfinger, supra note 10 at 17.
84 Id.
85 The Economic Impact Aid program targets funds for low income or non-English speaking children. Id., 5.
86 Categorical Aid, supra note 78.
87 Id.
88 17 Cal. 3d. 280 (1976).
89 Please see the Access to Equal Educational Opportunities Briefing Paper for a more detailed discussion of these issues.
90 Serrano I (1971); Serrano v. Priest (Serrano II (1976)), 135 Cal. Rptr. 345; Serrano v. Priest (Serrano III (1986)), 226 Cal. Rptr. 584.
91 Although not addressed within this paper, there are disparities in resource allocation on campuses that contain both "regular" school programs and "magnet" school programs.
92 Rodriguez v. Los Angeles Unified School District, Case No. C 611358, Los Angeles Superior Court, Statement of Decision, p. 8 (1992).
93 Amy Pyle, L.A. Schools Wrestle With Realities of '92 Money Pact, Los Angeles Times, A1, 20 (February 14, 1995).
94 The court defined "Basic norm resources as follows: "'Basic norm resources' means funds allocated from state or local general purpose revenue for teachers' salaries, school administrator salaries, pupil services, classified and office personnel salaries, instructional materials [sic] accounts, noon recreation programs, school advisory committee expenses, student data system supplies, and temporary personnel accounts. 'Basic norm resources' does not include custodial service expense." Rodriguez, supra note 92 at 5. According to Amy Bradley, LAUSD's practice of distributing general-purpose resources by way of a formula is a common practice. Amy Bradley, Equation for equality. Education Week, 14(2) September (1994).
95 Los Angeles Unified School District Document, 1994-95 Adjusted Final Budget, Section B -- School Staff Exhibit, p. B-2.
96 Teacher experience is considered to be a factor in promoting educational opportunity and educational achievement. Rodriguez, supra note 92 at 8 (1992).
97 The Consent Decree also dealt with issues of overcrowding and the provision of additional resources but these issues were dealt with in more speculative manners because of their dependence on future spending allocations. Although the Rodriguez case had originally focused on physical plant differences between schools, when it became clear that there was not enough money to address such differences the plaintiffs began to look at disparities inside the classroom. Here they discovered teacher flight in epidemic proportions - brand new instructors without any experience - and frequently without credentials filled classrooms in city's core. Those who stuck it out and gained seniority transferred to the suburbs. This picture has changed somewhat because of contracts that reward teachers who stay in a school for eight years. Implementation of Rodriguez decree may continue that trend by allowing poorer schools to hire more experienced teachers or use money to train existing staff and force richer ones to hire beginners. Pyle, supra, note 93 at 20.
98 Pursuant to the Consent Decree no teacher can be forced to transfer to a school in violation of his or her contract. The Consent Decree does not indicate how these changes are to be implemented and there are going to be obvious difficulties ahead for the district in trying to meet these goals.
99 The court addressed the issue of differentiated spending by identifying and defining "Average dollars per enrolled student" as follows: "'Average dollars per enrolled student" means the total of all the District's basic norm resources for a particular level of school (i.e., elementary, junior high/middle or senior high) divided by the student enrollment within that level of school, after setting aside a prudent reserve for the expenditures and contingencies required by paragraphs 15(b) and (16a) and (b) of this Consent Decree. It is understood and agreed that any unused balance of the prudent reserve shall be carried over to the following year's prudent reserve and shall not be used for other purposes." Rodriguez, supra note 92 at 5-6.
100 The United Teachers of Los Angeles (UTLA) objected to the original Consent Decree on several grounds: 1) that the "Decree establishes a rigid, lockstep requirement equal spending per student instead of a formula that would allow greater expenditures per student in schools that have greater needs"; 2) that the "Decree does not require intervention in low expenditure schools where low expenditures can be tied directly to incompetent management, internal staff divisions and/or high teacher turnover"; and 3) that the "Decree does not sufficiently address the problems of large/over crowded schools in a way that is fair and equitable." Moreover, UTLA expressed the concern that the implementation of the Consent Decree would cause a significant number of schools in poor and minority areas to be directly harmed by a loss of substantial resources: "Numerous school with special needs because of size, socio-economic background of students, and/or location are now faced with losing resources that they sorely need in order to serve their students." They pointed to 22 elementary schools that would be required to reduce their expenditures per pupil even though their student body is over 90% minority in each case. Letter from Helen Bernstein to Richard K. Mason, February 5, 1996. On file with the author.
101 Unfortunately, the other type of funding disparities are not created by direct state funding. These disparities exist because of differences in the affluence of the parents of a particular school district or the special nature of a particular school. In affluent school districts parents and businesses are known to join forces to provide additional funds or resources to their local schools. While no parent should be prevented from improving his or her child's education, as a result of these additional resources some children clearly receive special treatment and the disadvantages faced by poorer school districts are simply compounded.
102 The settlement agreement provides that compliance must be achieved by the 1997-98 school year. This allows for a five year phase in for the district to attempt to equalize teacher experience and other educational resources. Rodriguez, supra, note 92 at 9.
103 Id. at 14.
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