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Arizona's Students FIRST Legislation: Are There Winners and Losers

ProQuest Dissertations and Theses, 2011
Dissertation
Author: Kenneth R Baca
Abstract:
In Roosevelt v. Bishop (1994), Arizona public school districts and parents challenged Arizona's school financing system arguing that it was not "general and uniform" as required by the Arizona Constitution. The purpose of this study was to analyze Arizona's Students Fair and Immediate Resources for Students Today (Students FIRST) legislation, the remedy that resulted from the Roosevelt decision, empirically, and longitudinally. Three types of statistical analyses were conducted on a sample of 165 public school districts. Fiscal neutrality was measured for each of the eleven years of the study, to assess the association between the per-pupil Students FIRST funding level and the per-pupil property wealth. Multiple regression analysis was also conducted to assess if both property wealth and district size were associated with the distribution of Students FIRST funding. Finally, I analyzed the eleven-year average of the total Students FIRST funding distributed to school districts and assessed how the plaintiff districts ranked in the distribution. Overall, the findings revealed that Students FIRST met the fiscal neutrality standard in some, but not in all the categories and years of this study, per-pupil property wealth was only weakly related to, and district size was not associated with, Students FIRST funding. The analysis of average funding suggested that some property rich school districts benefited most from Students FIRST. These results suggest that the traditional measures used to assess the fiscal neutrality of operating funding may not be appropriate for assessing the fiscal neutrality of capital finance reforms. While the results of this study provide some suggestive evidence that Students FIRST did not fulfill the Court's mandate, additional research is needed as to whether or not Arizona's capital finance system has resulted in disparities in funding that fall short of the constitutional standard.

TABLE OF CON TENTS

Page

LIST OF TABLES

................................ ................................ ................................ .

ix

CHAPTER

1

INTRODUCTION

................................ ................................ .......................... 1

Statement of the Problem

................................ ................................ ....... 1

Purpose of Curre nt Study and Research Question

................................ . 2

A Brief History of A rizona’s School Finance System

........................... 4

Arizona Court Cases

................................ ................................ .............. 6

Roosevelt v. Bishop (1994)

................................ ........................... 7

Hull v.

Albrecht (199 7) and Hull v. Albrecht (1998)

................... 8

Students FIRST

................................ ................................ ...................... 9

B uilding Renewal

................................ ................................ ........ 10

Deficiencies Correction

................................ .............................. 11

New School Facilities

................................ ................................ . 11

Conceptual Framework

................................ ................................ ........ 12

Fiscal Neutrality

................................ ................................ .......... 13

Definition of Terms

................................ ................................ .............. 15

Summary of Chapter 1

................................ ................................ ......... 17

2

LITERA TURE REVIEW

................................ ................................ ............. 18

Introduction

................................ ................................ .......................... 18

School Finance Litigation Based on Issues of Equity

......................... 18

vi

Page

School Facilities Litigation Based on Issues of Equity and

Adequacy

................................ ................................ .................... 22

Ass essing School Finance Reforms

................................ ..................... 25

An Equity Measurement Model to Assess Fundin g for School

Facilities

................................ ................................ ...................... 29

Summary of Chapter 2

................................ ................................ ......... 36

3

METHODOLOGY

................................ ................................ ....................... 37

Introduction

................................ ................................ .......................... 37

Variables and Data Sources

................................ ................................ . 39

Population and Sample

................................ ................................ ........ 41

Very Small School Districts

................................ ........................ 43

High Impact Aid Districts

................................ ........................... 44

Descriptive Statistics

................................ ................................ ............ 45

Fiscal Neutrality Analysis

................................ ................................ .... 48

Total Students First Funds

................................ .......................... 51

Building Renewal

................................ ................................ ........ 52

Deficiencies Correction

................................ .............................. 52

New School Facilities

................................ ................................ . 53

Analysi s by Size of School Districts

................................ .................... 54

Analys is of Eleven - Year Average

................................ ....................... 55

Summary of Chapter 3

................................ ................................ ......... 55

vii

CHAPTER

Page

4

FINDINGS

................................ ................................ ................................ .... 56

Fiscal Neutrality Findings

................................ ................................ .... 56

Tota l Students FIRST Funding

................................ ................... 57

Building Renewal

................................ ................................ ........ 58

Deficiencies Correction

................................ .............................. 60

New School Facilities

................................ ................................ . 62

Summary of F indings for Fiscal Neutrality

................................ 63

Multiple Regression Findings

................................ .............................. 64

Total Stud ents FIRST

................................ ................................ . 65

New School Facilities

................................ ................................ . 66

A ssessing the Fiscal Neutrality of the Eleven Year Average

.............. 66

5

SUMMARY, DISCUSSION,

IMPLICATIONS AND CONCLUSIONS

... 69

Plaintiff Districts

................................ ................................ .................. 74

Bottom and Top School Districts According to Per - pupil

Property Wealth

................................ ................................ .......... 74

Bottom and Top School Districts According to Per - pupil

Total Students FIRST Funding

................................ ................... 75

Implications

................................ ................................ .......................... 75

Conclusion

................................ ................................ ........................... 78

REFERENCES

................................ ................................ ................................ ..... 81

viii

APPENDIX

Page

A

OMITTED SCHOOL DISTRICTS

................................ .............................. 8 6

B

SIZE C ATEGORIES OF SCHOOL DISTRICTS

................................ ........ 91

C

IMPACT AID SCHOO L DISTRICTS

................................ ......................... 93

D

M ULTIPLE REGRESSION STATISTICS

................................ .................. 96

E

ELEVEN - YEAR, PER - PUPIL AVERAGE OF TOTAL

STUDENTS FIRST

FUNDING AND PROPERTY WEALTH

......... 98

ix

LIST OF TABLES

Table

Page

1.

Summary of Variables

................................ ................................ .................. 40

2.

Average Per - pupil Students FIRST Funding, Per - pupil Property

Wealth and ADM

................................ ................................ ................. 46

3.

Fiscal Neutrality Statistics,

Total Students First Funding

............................ 57

4.

Fiscal Neutrality

Statistics, Building Renewal

................................ ............. 59

5.

Fiscal Neutrality Statis tics, Deficiencies Correction

................................ .... 61

6.

Fiscal Neutrality Stat istics, New School Facil ities

................................ ....... 63

7.

Relationship Between Total Students First (TSF)/New School

Facili ties, and Property Wealth/ADM

................................ ................. 65

8.

Per - pupil Average of Plaintiff School Districts in Roosevelt v.

Bishop (1994) ................................ ................................ ....................... 67

9.

Relationship Between the Eleven - year Per - pupil Average of Total

Students FIRS T Funding and Property Wealth

................................ ... 68

10.

Eleven Year Average o f Per - pupil PW and TSF Funding

............................ 7 1

11.

Median, Range, and Percentile Ranking -

Eleven - year Average

.................. 7 3

12.

Summary of Students FIRST Fu nding Distribution, 1999 - 2009

.................. 7 6

1

CHAPTER 1

INTRODUCTION

Statement of the Problem

When Thomas Jefferson first proposed the idea of a free, state - sponsored school system, he could not have predicted the legal challenges that have emerged regarding funding for quality pu blic school facilities. State legislatures have traditionally delegated the majority of the responsibility for funding public schools to local taxpayers

via property taxes

which, in many cases, has created disparities between property rich and property poo r districts. This disparity became the focal point of Roosevelt v. Bishop (1994), a challenge to Arizona’s capital funding scheme for public school facilities .

Arizona’s constitution provides for the creation and maintenance of a “general and uniform” public school system (Article XI , Section 1). In a series of lawsuits, school districts and parents have challenged the state’s school financing system in the state ’s courts, arguing that it was not “general and uniform” as required by the Arizona Constitution ( Roosevelt v. Bishop , 1994; First, 2007). In 1994, the Arizona Supreme Court ruled that, to comply with the general and uniform provision of the state’s consti tution, the legislature must fund public schools in a manner that does not create disparities among schools, districts, or communities. Although this ruling applied to all areas of school finance, in

Roosevelt

the Court found that

only the capital funding scheme for school facilities was

inequitable and thus, unconstitutional .

2

Purpose of Current Study and Research Question

The purpose of my study was

to analyze Arizona’s Students Fair and Immediate Resources for Students Today (Students FIRST) legislation, the remedy that resulted from Roosevelt v. Bishop

(1994), empirically, and longitudinally. I investigate d

whether or not Students FIRST created a nd maintained a

general and uniform capital finance scheme. In addition, I assess ed

if the size and wealth of

Arizona school districts

were significant predictors of Students FIRST funding . The research question

that guide d

this study wa s as follows: Did Students FIRST create a general and uniform capital finance scheme between fiscal year 1999 and fiscal year 20 09?

My longitudinal analysis of Students FIRST had four components. First, I assessed the fiscal neutrality of Students FIRST by analyzing the capital funding provided to every district in the state under the legislation between 1999 and 2009 . Second, I as sessed if there was a relationship between property wealth and district size and the distribution of Students FIRST funding that suggested that the funds were allocated in a manner that was not general and uniform. Third, I assessed the fiscal neutrality o f Students FIRST by analyzing the eleven - year average of total funding distributed to school districts

F inally, I used the eleven - year average of the Total Students FIRST funding that was disbursed to school districts to analyze how different categories of

districts ranked

in the distribution. These analyses allowed me

to provide a preliminary assessment of

the changes in capital funding that resulted from Students FIRST. My dissertation is

the first

3

empirical study of Students FIRST. As Arizona schools exp erience cuts in education funding , my analysis may prove

useful in determining whether or not capital funding for public school facilities is general and uniform. My analysis

also contribute s

to the growing body of research that assesses court - ordered legi slative remedies related t o capital finance reform.

M y research provide s

a rigorous and systematic analysis of Students FIRST for

Arizona policymakers to consider as they make decisions about education funding during a period of economic decline.

Finally, my findings also suggest there are limitations with the standard that is currently used in school finance to assess the fiscal neutrality of capi tal funding reforms.

I introduce my topic and provide background information in Chapter One , in which I summari ze the history of Arizona’s finance system, the court cases that forced a reform of the capital finance scheme, and the Students FIRST legislation that remains in effect today. I present a conceptual framework to conclude the first chapter and I define key

terms used throughout my study. In the second chapter, I present a review of the literature focusing on: 1) school finance litigation based on issues of equity; 2) school facilities litigation based on issues of equity and adequacy; 3) the research assess ing school finance reforms; and 4) an equity measurement model to assess funding for public school facilities.

I discuss my

research design in Chapter Three and in the final two chapters I present my results and the implications of my study.

4

A Brief History of Arizona’s School Finance System

Arizona’s overall school finance system provides funding based on an equalization formula. A state’s funding formula is said to be equalized when funding by the state is provided in inverse relationship to a distr ict’s property wealth (Odden & Picus, 2008). Arizona’s equalization formula has several components which work as follows. The state provides each school district with a base support level based on equal dollars per weighted students enrolled. Weights are u sed to account for district size, location, and grade span 1 . Other weights are added to the base support level to account for students with special needs and for districts that enroll students in kindergarten through third grade. These added weights provid e additional money to districts. Enrollment is measured by

the Average Daily Membership (ADM) which is the average number of students enrolled in a district during the first 100 days of the previous school year. A balance between local property tax rate s

a nd state and county equalization assistance generates the necessary revenue limit for each district (AASBO, 2010). The Arizona Legislature places limits on the amount of funding that can be generated without voter approval through the collection of propert y taxes from each school district. Because high wealth districts are able to raise substantial revenues via property taxes within their area, they receive less state and county assistance compared to low wealth, property poor districts that require greater

1

Additional adjustments account for districts with fewer than 500 students, for districts who are designated as “isolated”, and for districts that serve preschool students with disabilities. Districts that serve students in grades 9 - 12 have additional weights to account for the higher costs

associated with educating students in this grade span.

5

levels of state funding. Arizona’s equaliza tion formula calculates a district’s Revenue Control Limit (RCL), Capital Outlay Revenue Limit (CORL), and Soft Capital Allocation (SCA). 2

Districts can raise additional funds through voter - approved overrides and

bond issuance; districts are also eligible for additional federal money, such as Title I, based on the economic needs of its community. 3

Annually, each district determines where to allocate their RCL, CORL and SCA funds and must adhere to the limits that are

set for each category. In other words, once a district adopts its annual budget, that district is prevented from using M&O funds for capital expenditures and capital funds for M&O expenditures. Likewise, funds generated through voter approved overrides

and bonds are restricted to the purposes described in the ballot language and in the voter pamphlet. M&O overrides are for M&O expenses. Bonds and capital overrides are for capital expenses. Both M&O and capital overrides last for a maximum of 7 years and

must be reapproved by voters for districts to continue receiving these revenues. The use of f ederal funds, such as Title I, are also restricted and must supplement the district’s annual budget.

2

The RCL provides funds for the Maintenance and Operation (M&O) budget which is used for expenditures such as salaries, benefits, and expenditures excluding cap ital expenses. The CORL provides funds for the Unrestricted Capital budget to maintain facilities, and to purchase furniture and equipment. The SCA is used for short - term capital expenses to meet academic standards including textbooks, instr uctional aides and technology.

3

Through special elections, voters can authorize additional property taxes to: increase, up to 15%, a district’s M&O budget for M&O expenses; authorize debt payment to issue and sell bonds for capital purposes; increase tax revenues for c apital expenses. Title I money is based on the level of poverty within a school district.

6

Prior to 1998, local districts’ capital funding for school fa cilities was heavily dependent on the sale of general obligation bonds as capital

funds were insufficient to maintain school facilities. This system created disparities as property poor districts could not generate sufficient funding to provide adequate fa cilities even though the residents of these districts often paid higher property taxes than their counterparts in districts with greater property wealth (AASBO, 2010). In 1992, a group of poor districts and parents challenged this system of school financin g in the state courts. In Roosevelt v. Bishop (1994)

the Arizona Supreme Court ruled that the state’s system for capital funding of facilities and equipment was unconstitutional because it violated the provision in the state constitution that required the state to provide a “general and uniform” system of public education (Arizona Constitution, Article XI, Section 1). The Supreme Court ordered the legislature to create a new capital funding scheme to comply with the C onstitution. In 1998, the legislature pa ssed Students FIRST which created the current school facilities funding scheme that is used to allocate capital funds to school districts from the state. Students FIRST funding is not equalized ;

Arizona provides Students FIRST funds to all public school d istricts, regardless of wealth.

Arizona Court Cases

Article XI, Section 1 of Arizona’s constitution requires the legislature to provide the state’s citizens with a “general and uniform” educational system (Arizona Constitution). Subsequent sections provide

the basic outlines of the

7

school financing system and empower the legislature to delegate powers and responsibilities to local school districts. In Shofstall v. Hollins (1973), a legal challenge was launched by Arizona taxpayers and school children in a p roperty poor school district. They claimed the entire school finance scheme resulted in lower quality education and higher tax burdens in property poor districts. Although the Arizona Supreme Court recognized education as a fundamental right protected by t he state’s constitution, and reaffirmed the general and uniform clause, they ruled that the state’s school finance scheme was constitutional. The general and uniform provision under Article XI, Section 1 became the focus of Roosevelt .

Roosevelt v. Bishop ( 1994)

In Roosevelt , property poor districts and parents challenged the state’s system of school financing a second time. In its deliberations the Supreme Court narrowed the scope of the case to capital financing. Ruling in favor of the plaintiffs, the Court described the state’s school finance system, taken as a whole, as complicated. The ability for districts to fund their schools depended on the amount of property tax revenue they could generate ( Roosevelt v. Bishop , 1994). While the state claimed tha t the financing of public schools was the responsibility of school districts, the court argued that the legislature must establish and maintain a public school system

( i.e., the structure of a K - 12 and higher education system) and then fund that public sch ool system in a manner that is general and uniform.

The Court noted the disparities in capital funding between districts and

8

argued that the quality of schools’ facilities and equipment was directly proportional to the value of the property within each dis trict. Property poor districts had higher tax rates but were unable to generate enough funds to meet their capital needs, whereas property rich districts had lower tax rates and an abundance of capital funds. According to the Court, this funding scheme pro duced a public school system that was not general and uniform because it directly caused substantial capital facility disparities across districts. While the Court did not directly address the issue of adequacy, it did note that there was a minimum thresho ld that all districts must meet: “Even if every student in every district were getting an adequate education, gross facility disparities caused by the state’s chosen financing scheme would violate the uniformity clause” ( Roosevelt

v. Bishop , 1994, p .7). T he Court ordered the legislature to reform the existing capital finance system in order to create a more equitable funding scheme for school facilities. In 1996, the Court ruled that the legislature’s initial attempt to amend the financing system was inade quate because the legislation did not substantively alter the overall funding scheme. As I explain below, the legislature made additional attempts to comply with the Roosevelt

decision. The last of these, Students FIRST, created the capital financing syste m for public school facilities in place today.

Hull v. Albrecht (1997) and Hull v. Albrecht (1998)

In 1997 ,

Governor Hull asked the Court to evaluate the Assistance to Build Classrooms (ABC) program, the legislature’s second attempt to comply

9

with the Roos evelt order. The Court ruled that the ABC program did not meet the requirements of Article XI because it “delegated to the districts the responsibility to provide adequate capital facilities,” continued to create “substantial disparities” among districts, and ABC did not create nor did it meet an adequate facilities standard ( Hull v. Albrecht , 1997, p. 13.) In response, the legislature passed Students FIRST which the Court assessed in 1998. The Court determined that Students FIRST established a system to id entify and fund adequate capital facilities ( Hull v. Albrecht , 1998). However, because this funding scheme allowed districts to opt - out of state funding and did not allow participating districts to issue general obligation funds, the Court found that the s ystem continued to create two classes of districts and, thus, failed the general and uniform test. The state amended the Students FIRST program to comply with the Court’s ruling in 1998 by: 1) funding all school districts; and 2) allowing voters to continu e authorizing overrides and bonds for their school facilities. Students FIRST continues to be Arizona’s system for providing capital financing to public school districts for school facilities. The Students FIRST program is funded by three main sources: 1) legislative appropriations to the SFB; 2) revenues generated by the Proposition 301 sales t ax; and 3) state land revenues.

Students FIRST

Students FIRST established the Schools Facilities Board (SFB) in 1999 which is charged with distributing capital funds

on behalf of the state, for facilities to public school districts and ensuring that districts maintain minimum

10

facility standards. The SFB adopted Building Adequacy Guidelines which established minimum standards for existing and new school facilities in A rizona and minimum classroom space for students enrolled. The SFB administers three capital funds

for three programs

on behalf of the state that are separate from, and in addition to, the CORL funding I described earlier: Building Renewal, Deficiencies Cor rection, a nd New School Facilities. The state legislature decided to fully fund Students FIRST without an equalization formula. All of the funds from Students FIRST are distributed as described below without any consideration of the property wealth of each

school district. Likewise, all three funds are administered separately; that is, the SFB awards districts funds for each program without considering the funds that district s

may or may not be awarded from any of the other Students FIRST programs.

Building

Renewal

The Building Renewal fund was established to maintain the adequacy of school facilities once minimum standards are achieved. Prior to fiscal year 2008, the SFB provided funding to school districts for the maintenance of school facilities based on a building’s square footage, age, and student capacity. In fiscal year 2008 the state cut funding to the Building Renewal fund and since fiscal year 2009 the state has not funded Building Renewal as originally designed. School districts must now apply for a Building Renewal Grant which is awarded based on priority

need as determined by the SFB.

11

Deficiencies Correction

The Deficiencies Correction fund was used to bring all existing school facilities to minimum standards by 2004. In

2004 the Deficiencies Cor rection fund was renamed

the Emergency Deficiencies Program, an application - based program where districts must apply for funding from the SFB to correct facility deficiencies that threaten the immediate safety and operation of a school. If a school distric t has facilities that are below the Building Adequacy Guidelines, the SFB provides full funding to correct the deficiencies.

New School Facilities

The third program under Students FIRST is the New School Facilities fund which is used to construct s chool

s p ace

in districts based on the Building Adequacy Guidelines. If a district must

construct additional school space to meet facility standards and/or to address increased student enrollment, the SFB provides full funding; this includes the construction of new

schools.

In order for a district to be eligible to receive funds for new school facilities, they must meet a set of criteria based on that district’s enrollment projections and the additional square footage that will be needed to maintain the established facility standards. The SFB distributes new school facilities funds to school districts based on the following formula: (number of students) x (square footage) x (cost per square foot) = district allocation. In addition to the funds for building constructi on calculated by this formula, if a district must acquire land for new construction, the land costs are funded by the SFB.

12

To summarize Students FIRST, the state provides full funding to all school districts in the three categories described above. Unlike Arizona’s overall public school funding scheme where property wealth is taken into consideration in determining the level of state funding provided to districts, Students FIRST funding is not based on an equalization formula. As ordered by the Arizona Supr eme Court, the State allows districts to raise additional dollars beyond Students FIRST funding to build, remodel, and/or renovate schools that exceed the minimum standards through voter - approved capital overrides and general obligation bonds ( Albrecht,

19 98) .

Conceptual Framework

The conceptual framework that I

use d

for my analysis dr e w from three equity concepts that are widely used

by researchers to assess states’ school finance schemes: fiscal neutrality; horizontal equity; and vertical equity (Berne, &

Stiefel, 1994; Rolle & Liu, 2007; Toutkoushian & Michael, 2007; Rolle, Houck, & McColl, 2008; Odden & Picus, 2008; Glenn, Picus, Odden ,

& Aportela, 2009; Odden, Picus ,

& Goetz, 2010). Because the Roosevelt

(1994) decision centered on the general and unifo rm provision of Arizona’s constitution, I focused

my conceptual framework on

fiscal neutrality in order to assess the equity of facilities funding in Arizona. As I explain below, of the three concepts described above, fiscal neutrality is the concept that is most consistent with the way the Arizona Supreme Court interpreted the meaning of “general and uniform.” Currently, there are no measures specifically designed

to assess the adequacy of school facilities

13

(Glenn, et al, 2009). Although my study d id

not s eek to analyze the adequacy of school facilities in Arizona, it was

an important aspect of court decisions regarding school funding and is a facet of Students FIRST. Therefore, I also address ed

issues of adequacy

in the literature review provided below.

Fi scal Neutrality

“Traditional fiscal neutrality analysis assesses the relationship between current operating expenditures per pupil and property wealth per pupil” (Odden & Picus, 2008, p. 64). In a school

finance system that is fiscally neutral, there shoul d be no relationship between the funding level of each school district and the property wealth of each school district (Odden & Picus, 2008; Glenn, et al . , 2009).

The concept of fiscal neutrality, originally referred to as Proposition I, was developed in the late 1960’s by Northwestern University Law Professor John Coons and his two students, William Clune and Stephen Sugarman, as a legal strategy for challenging public school finance inequities ( Minorini & Sugarman , 1999). Coons and his students were amon g a group of lawyers that were developing legal strategies aimed at

addressing the funding inequalities associated with differences in property wealth . Coons, Clune, and Sugarman argued that districts in high property wealth communities

could easily increa se property tax revenues to support their local schools. Conversely, school districts that were located

in property poor communities

generated

less money per - pupil

through what were often higher property tax

rates than more advantaged districts . Although m any states offset this inequity via state aid formulas, Coons and his

14

team argued that property rich districts continued to have enormous wealth advantages , that poor districts had higher tax burdens than their wealthy counterparts, and that

this was an un constitutional form of wealth discrimination ( Minorini & Sugarman , 1999). Coons, et al. argued that a state’s finance scheme could be fiscally neutral through the use of a state aid formula that made every district equally wealthy. O nce this was accomplish ed, the state could permit districts to set tax rates as high or as low as they wished, and thus maintain

the traditional importance of local control (Minorini & Sugarman , 1999 ).

The fiscal neutrality theory played a role in two major school finance cases that I will refer to later in my literature review: Serrano v. Priest (1971) and Rodriguez v. San Antonio Independent School District

Full document contains 121 pages
Abstract: In Roosevelt v. Bishop (1994), Arizona public school districts and parents challenged Arizona's school financing system arguing that it was not "general and uniform" as required by the Arizona Constitution. The purpose of this study was to analyze Arizona's Students Fair and Immediate Resources for Students Today (Students FIRST) legislation, the remedy that resulted from the Roosevelt decision, empirically, and longitudinally. Three types of statistical analyses were conducted on a sample of 165 public school districts. Fiscal neutrality was measured for each of the eleven years of the study, to assess the association between the per-pupil Students FIRST funding level and the per-pupil property wealth. Multiple regression analysis was also conducted to assess if both property wealth and district size were associated with the distribution of Students FIRST funding. Finally, I analyzed the eleven-year average of the total Students FIRST funding distributed to school districts and assessed how the plaintiff districts ranked in the distribution. Overall, the findings revealed that Students FIRST met the fiscal neutrality standard in some, but not in all the categories and years of this study, per-pupil property wealth was only weakly related to, and district size was not associated with, Students FIRST funding. The analysis of average funding suggested that some property rich school districts benefited most from Students FIRST. These results suggest that the traditional measures used to assess the fiscal neutrality of operating funding may not be appropriate for assessing the fiscal neutrality of capital finance reforms. While the results of this study provide some suggestive evidence that Students FIRST did not fulfill the Court's mandate, additional research is needed as to whether or not Arizona's capital finance system has resulted in disparities in funding that fall short of the constitutional standard.