## Facts

- New Jersey funded elementary and secondary public schools primarily through local property taxes, supplemented by state aid.
- Large disparities in district property wealth meant property-poor districts could not raise revenues comparable to property-rich districts without substantially higher tax rates.
- In 1970, the Legislature enacted the State School Incentive Equalization Aid Law to reduce disparities, but state support remained below the law’s anticipated level and did not eliminate unequal educational conditions.
- Public school students from property-poor districts sued state officials responsible for the funding system, alleging unconstitutional inequality in educational opportunity.
- Plaintiffs claimed violations of federal and state equal protection guarantees and the New Jersey Constitution’s requirement that the State maintain a “thorough and efficient system of free public schools” for children ages 5–18.

## Issues

1. Whether New Jersey’s property-tax-centered school-finance system, producing substantial inter-district funding disparities, violates federal or state equal protection guarantees.
2. Whether the system violates the New Jersey Constitution’s “thorough and efficient” education clause by failing to provide constitutionally adequate educational opportunity statewide.
3. Whether the education clause requires statewide equality of taxpayer burdens through exclusive state-level funding, or instead requires equal educational opportunity while allowing local variation in taxation and supplementation.

## Decision

- The New Jersey Supreme Court held the existing school-finance system unconstitutional under the state “thorough and efficient” education clause.
- The Court declined to rest its judgment on federal equal protection and did not base relief on state equal protection.
- The Court rejected the trial court’s view that the Constitution requires statewide uniform tax burdens or exclusive reliance on uniform state taxes to fund schools.
- The Court affirmed the constitutional violation but modified the remedy to emphasize equal educational opportunity and to preserve legislative flexibility in selecting a compliant funding method.
- Relief was prospective: the Court withheld immediate enforcement and allowed time for legislative action, reserving the possibility of further judicial measures if compliance was not achieved.

## Legal Principles

- The New Jersey Constitution’s “thorough and efficient” clause imposes an enforceable duty on the State to maintain and support a system of public education that provides equal educational opportunity at least to a constitutionally adequate minimum.
- Educational opportunity may not depend on the relative property wealth of a child’s local school district, even if the State permits a role for local property taxation.
- The education clause does not require identical per-pupil spending in every district and does not constitutionalize statewide equality of taxpayer burdens.
- Courts may declare a school-finance system unconstitutional while granting the political branches time and discretion to craft a remedy, so long as the constitutional minimum is met.

## Conclusion

The court invalidated New Jersey’s then-current school-finance scheme because reliance on unequal local property wealth denied children in poorer districts the equal educational opportunity required by the state “thorough and efficient” clause, while leaving the Legislature discretion to choose a funding mechanism and declining to require statewide uniform tax burdens.


Robinson v. Cahill, 62 N.J. 473, 303 A.2d 273 (N.J. 1973)