Property Taxes and Inequitable Spending: A Survey of Education Funding in Illinois

Yanina Villagomez, Alice Lee, Benjamin Escobar, Charles Lally, and Jordan Evans-Kaplan

Vol. 1 No. 1 – Spring 2019

I. Abstract

Any study into law and policy inevitably makes one truth abundantly clear: The rules of a game describe more than just its structure, they define the boundaries and limitations of the players’ actions within. A closer look into public school funding in Illinois betrays the same reality. As a result, it is important to study the “rules” surrounding education funding in order to better understand the artificial constraints placed on individuals in the public school system. To study the effects of funding school districts with property tax revenue, we’ve taken a multifaceted approach. First, we explore the disproportional effects of property tax-based funding. Second, we follow a legal perspective of relevant precedent, and then, lastly, describe the economic roots of the issue. By using this three-pronged approach, we seek to describe the historical relationships this policy has within Illinois, the application/consequences of it in the present, and the role it ought to have in the future of Illinois public education.

II. Introduction

The use of property taxes to fund public high schools in Illinois has a disproportionately negative effect on students in low-income communities. Throughout this analysis and investigation of this issue, we will be using the term “low-income” to refer to the same concept established by Illinois Report Card, the annual report released by the Illinois State Board of Education that displays how each school and district in the state are performing on various educational goals. Thus, “low-income students” shall be understood as meaning students who “are eligible to receive free or reduced-price lunches, live in substitute care, or whose families receive public aid.”[1] It is also critical to note that we are studying exclusively public schools, defined as “a school maintained at public expense for the education of a community or district.”[2]

The current funding system, which is reliant on property taxes, does not promote equity among students in the state of Illinois. Students in low-income communities have schools that see far fewer resources than their wealthier counterparts, primarily due to the system being reliant on property taxes. Because homes in low-income communities will naturally have lower values than those in wealthier communities, the system will naturally benefit the wealthy and negatively affect those in low-income communities. This gap is not only automatically created by a funding system reliant on property taxes, but is self-reinforcing. Because schools in low-income communities receive fewer resources, they are likely to see lower student performance manifested in poorer test scores, higher dropout rates, and lower rates of college admission, to name a few parameters. This in turn will allow the system to perpetuate, as the students will not be receiving the educational support they need to effect change within this system.

One significant obstacle to be understood on the subject of disproportionate effects and inequitable school spending is the unique issues that face rural versus urban districts. Separate needs and costs in transportation and material resources, major disparities in population, and racial segregation are but a few challenges that plague rural and urban communities in different ways. While the accepted theory of school funding establishes that these unique challenges can be addressed severally and responsibly via local property tax rates, that theory is not seen in reality. These differences are not sufficiently resolved by their property tax rates, and in turn their school funding, as both rural and urban areas experience varying areas of wealth and poverty. The minimum amount of money needed, per student, to provide basic educational needs is simply not met through property taxes.

Another important delineation to be made in the frame of this argument is the racial component of low-income communities. Often, due to already commonly known and widely discussed issues of marginalization, discrimination, and systematic inequality, low-income communities have large populations of people of color. As such, an additional distinction we make with this argument is that property tax-based funding for public schools not only disproportionately affects low-income communities, but also disproportionately affects people of color. Thus, property tax-based funding can be thought of as inequitable both in terms of class status as well as race.

Our analysis and investigation of this issue constitute a look at the general legislation of property tax funding at the state level in Illinois, as well as a comparison between Illinois counties at varying levels of wealth as well as a comparison between urban and rural counties. The measures we will use to gauge student performance will rely primarily on graduation rates, college admission rates, and test scores. Through an analysis that combines an understanding of both Illinois legislation concerning property tax-based education funding in Illinois and how it plays into student performance in counties with differing levels of wealth in Illinois, we will see how the use of property taxes to fund public high schools in Illinois has a disproportionate negative effect on students from low-income communities.

III. Previous Rulings on School Funding

San Antonio School District v. Rodriguez established an important focal point for the way the the courts addresses education. The case was focused on the inequalities facing low-income communities that were systematically affected by the school funding methods in the state of Texas in the 1970s. However, the Supreme Court stated that education was not a fundamental right protected by the Constitution, as it is not explicitly mentioned. The dissenting opinion was given by Justice Thurgood Marshall who claimed that education is a fundamental right and cited prior Supreme Court rulings. He stated that education was fundamental to a person’s ability to participate intelligently and effectively in the political process and exercise their Constitutional rights. Justice Marshall states that because of the wide disparity in funding, educational opportunity was widely different as well; this constituted, in his view and dissenting opinion, inequality ant not “gross inadequacy” which the majority ruling implied. It was not disputed by the majority opinion that discrimination had occurred but that the group discriminated against was based on geography (“property-poor” areas that received inadequate funding). The plaintiff used the Supreme Court’s holding in Brown v. Board of Education in an attempt to demonstrate the fundamental right to equal education, which was denied to low-income residents of Texas. The Brown v. Board of Education holding states, “In these days, it is doubtful that any child may reasonably be expected to succeed in life if he is denied the opportunity of an education. Such an opportunity, where the state has undertaken to provide it, is a right which must be made available to all on equal terms.” However, the Court argued that the 14th Amendment does not apply in the San Antonio School District v. Rodriguez case because “poor people” are not a suspect class, which indicated that the system of funding in California was not created specifically to discriminate against people of lower incomes.[3]. The majority opinion stated that “poor people” were not a suspect class because occasions of discrimination were based on wealth relative to its surrounding communities and it was not “shown to discriminate against any definable class of ‘poor’ people.”[4] Suspect classes are protected under the 14th Amendment’s Equal Protection Clause. The explicit Constitutional protection of a group of people is necessary to be provided strict judicial scrutiny. Because the poor are not explicitly mentioned in the Constitution, the court did not uphold that they were being targeted as a suspect class. Following Rodriguez and Brown, cases in several states challenged the constitutionality of funding public education through property taxes. The results have differed based on the Constitutions of each given state. In efforts to change the system of school funding through property taxes, several lawsuits have attempted to challenge the constitutionality of the practice. The cases address each individual state’s constitution and have been met with varying degrees of success.

The foundation and backbone of a nation’s prosperity is derived from the work of its citizens. While Americans can all agree on the value of the education system, lawmakers disagree on the proper way to fund public schools. An admirable attempt at structuring public school funding arose between 1971-1977 with Serrano v. Priest, three California Supreme Court opinions regarding the financing of public education. The case was originally a class action suit on the part of all California public school students. The funding system required families to pay different tax rates dependent on school district residency. The plaintiffs claimed that this system was discriminatory. Up to this point, the California school system had been depending on local property taxes as the primary vehicle to fund public education, and it was argued that this resulted in widespread disparities of school revenue and, consequently, inequity in the quality of education. The California Supreme Court agreed with the plaintiffs in Serrano I, and found that the “funding scheme invidiously discriminates against the poor because it makes the quality of a child’s education a function of the wealth of his parents and neighbors.”[5] Serrano I essentially used the equal protection clause of the 14th Amendment to strike down unequal public school funding through collecting property taxes.

School funding is not an issue isolated to a select few states in the union; it is a national problem. Since the 1970s, advocates for educational equality have filed numerous school finance lawsuits and while some progress has been made, there are still large disparities in funding between schools in high-poverty districts and low-poverty districts.[6] Serrano v. Priest succeeded where several other states, including the state of Illinois, has failed.

IV. Illinois

In Illinois, the use of property taxes to fund education has been challenged as a contradiction of Article X of the state constitution, which states that “the State shall provide for an efficient system of high quality public educational institutions and services” (Article X). They claimed that using property taxes indirectly affects people in low-income communities, thereby making “poor people” a suspect class. This was disputed by the state because the disparity between high- and low-income communities was not seen as specifically disproportionately affecting low-income people. The people living in low-income communities consist of “(1) persons whose income falls below the legally recognized poverty level; (2) persons who are simply poorer than others; or (3) persons who, irrespective of their personal incomes, happen to reside in school districts with relatively lower property values.”[7] According to Watson, inequitable funding remains unfixed because of the broad scope of the problem. If legislation is passed based on the three categories outlined above, thereby creating a suspect class, it would be too large “suggesting equal funding of all state-funded civil services in general.” If only one of these is chosen, the problem would not addressed in its entirety. Choosing either option would violate the equal protection clause.[8]

While their assessment of the residents living in low-income communities may be correct, the disparity between the school funding continues to be a problem, and their reasoning does not negate the differences in funding. The use of property taxes for school funding can only go so far. The number of taxes that can imposed on properties is limited by tax districts. According to the Property Tax Extension Limitation Law (PTELL), taxation cannot exceed a 5% growth or the annual change in the U.S. Consumer Price Index.[9] If a higher tax is desired, voters will have to approve it. As of 2017, 33 counties have passed PTELL in referenda. Despite PTELL, there is a finite amount of funding that can come from property taxes, especially in low-income communities.

In addition to local property taxes, a portion of public schools’ funding comes from the General State Aid (GSA) which supplements local funding and is allocated based on two grants.[10] One of the grants gives enough funding to assist in reaching the Foundational Level, which has been set at $6,119 per pupil. The Foundation Level is minimum amount of funding required per student to provide “basic educational needs.”[11] No school district receives the full amount because they receive funding from local sources (like property taxes) and the state funds, in this grant, are used primarily to bring a school’s funding closer to the minimum required. The second GSA grant is awarded based on the proportion of low-income students in a given school district.[12] The more low-income students, the more money a school district receives. The inconsistencies of how funds are appropriated show us the reasons why the way we fund school in Illinois must change. Over the last several years, many schools did not reach even the Foundational Level of funds, leaving many schools with less funding than necessary per student. The second grant, meant to provide additional funding to schools with high numbers of low-income students, does not take into account the local wealth of the area. Theoretically, two schools in districts of unequal wealth with an equal proportion of low-income students, may receive the same amount of funding from this grant.[13]

Another of the major problems with the grants from the state of Illinois is that they have, quite simply, fallen short. In the past several years, the amount of money appropriated is less than the amount of the GSA request; usually, when this occurs, the state provides the largest percentage of the grants that appropriations will allow.[14] Under the 2017 Evidence-Based Funding for Student Success Act, The Illinois State Board of Education is responsible for setting an ‘adequacy target’ for every public school district. A school district’s adequacy target represents the dollar amount it would cost to provide education for every student in the district.

This target value is determined based on “as many as 34 factors essential to a high-quality education,” but, broadly speaking, it takes into account the material costs associated with education as well as the institutional costs of paying teachers and administrators.[15] A district is at 100% capacity to meet expectations when the adequacy target can be met entirely by funding from property taxes. In 2016, for example, even after increasing appropriations after a shortfall, the amount of money provided only reached 92% of what was due, which resulted in a deficit of $397 million.[16] This lack of funding is detrimental to local educational programs and exposes the failure of the Illinois education funding system. According to a 2018 study, Illinois was found to be the most regressive state with regard to school funding.[17] The disparity between state and local funding in high and low-income communities was 22%, worse of every other state.[18]

V. Illinois Extremes

To get an idea of the disparities and differences between counties and school districts of varying wealth, we must take time to explore and analyze examples of two types: wealthy counties and low-income counties. An examination of various factors such as property tax rates, funding per student, etc. will afford us a clearer picture and base frame to understand the issue of disproportionate school funding in the state of Illinois.

A. Wealthy Counties

Historically, Illinois’ economy and state-funding has long had the reputation of being one of the worst-handled in the country. With a total of 102 counties and the third-largest city in America, Illinois shelters the highest overall tax burden in the nation, and this burden far surpasses all other states in the Midwest.[19] A large contributing factor to this hardship comes in the form of property taxes: a tax on real estate or other forms of property whereby the money is used for funding essential government functions — water, sewage, infrastructure, and most of all, education. Illinoisans pay the second-highest property taxes in the country, with New Jersey taking the trophy at number one.[20] While it’s not an uncommon practice for states to funnel money to schools by collecting property taxes, it creates a disadvantageous effect for students in the state of Illinois, where rich and poor neighborhoods are highly segregated. The population density places a heavy concentration of the state’s overall population in the city of Chicago and its surrounding suburbs, where a large percentage of the state’s wealth is also located.[21] A system of property tax-funded schools, then lends a disproportionate advantage to students living in wealthier counties than in poorer counties, given higher property taxes are able to fund better resources and in essence, a better education.

Based on per capita income and median household income, the two wealthiest counties in Illinois are Lake County and DuPage County. In 2017, Bloomberg published “America’s 100 Richest Places,” and of the 11 Chicago suburbs that made the list, six were from Lake or DuPage County: Lake Forest, Hinsdale, Long Grove, Oak Brook, Hawthorn Woods, and Lake Bluff.[22] The concentration of wealth is centered in these two counties in the state, and evidently, in their schools as well. Lake County has some of the highest property taxes in the state with a tax rate of 2.78%, compared to the state average of 2.32%.[23] A look at some of the school districts in the county will clearly show the overfunding and abundance of resources at their disposal. The connection between school funding and student performance is also evident in the date provided by the Illinois State Report Card. Adlai E. Stevenson High School District (HSD) 125 is at 168% financial capacity to meet expectations, with $84 million when the adequacy target lies at $50 million. Seventy-eight percent of students test proficient or higher on the SAT ELA section and 81% test proficient or higher on the SAT mathematics section, compared to the state’s respective averages of 37% and 34%. Barrington High School in Community Unit School District (CUSD) 220 is at 107% financial capacity to meet expectations, $110 million with an adequacy target of $100 million. Sixty-eight percent of students test proficient or higher on the SAT ELA and 65% in SAT Mathematics, both higher than the state’s overall numbers.

FIGURE 1.1

Fig. 1.1 above shows the district demographic breakdown, local > resources, and funding levels of of Adlai E Stevenson District 125 > within Lake County, IL. The district demographic breakdown shows that > Adlai E Stevenson Dist 125 has a low-income rate 38 percentage points > lower than the average in Illinois, as well as 11 percentage points > fewer students of color. Further, the local resources shows that it > has a slightly lower property tax, but receives $19,965/student, > 288.9% higher than the Illinois average. As a result, the district is > classified “adequately funded” with a funding 168% above its adequacy > target.[24]

DuPage County has a lower property tax rate than Lake County, at 2.22%, but still shows the same kind of trend of good academic performance in a wealthy county with higher property taxes.[25] Naperville CUSD 203 is at 117% financial capacity to meet expectations, $230 million with an adequacy target of $190 million. Sixty-seven percent of the high school students in this district score at least proficient on the SAT ELA and 69% at least proficient on the SAT Mathematics. Hinsdale Township HSD 86 is at 134% financial capacity to meet expectations, $73 million with an adequacy target of $54 million. Sixty-seven percent of this district’s students test proficient or higher on the SAT ELA and 64% test proficient or higher on the SAT Mathematics. Of the four school districts mentioned, all four are above 100% for meeting the necessary funding to provide a quality education. Of the four school districts mentioned, all four have student achievement above 50% on standardized tests that measure how well-prepared they are for college. The link between high student performance and paying higher property taxes cannot be ignored.

FIGURE 1.2

Fig 1.2 displays a comparison of both demographics and resources > between the state of Illinois and the School District of DuPage HSD > 88. For demographics, school districts see higher proportions of > students of color, with a 9% difference compared to the state of > Illinois. Illinois sees higher proportions in low-income students and > in English learners, with a 4% and 4.6% difference, respectively. For > resources, Illinois sees .7% over the school district in property tax > rate, and the school district sees $4,350 over the state of Illinois > for actual resources derived from property taxes.[26]

B. Low-Income Communities

The insufficiency of a property tax-funded education system becomes apparent in counties where a large proportion of the population comes from low-income households. The disparity in funding, and the related decrease in academic performance, is most egregiously visible in rural school districts. But first, it is important to bear in mind that the state government of Illinois has persistently underestimated costs of education that uniquely impact rural areas, and that the 2017 Evidence-Based Funding for Student Success Act has done little to remedy this. For example, legislators in Springfield were unable to reach a consensus as to how transportation costs could be integrated into the funding formula.[27] This failure to arrive at a suitable policy solution disproportionately affected rural students, of whom only 2.7% live within one mile of their school (versus 21.9% in urban areas).[28] The Illinois Legislature concluded that, in the future, transportation costs would be left “out of the integrated formula and maintain[ed] as a categorical reimbursement.”[29] This is especially troubling, given that the reimbursement fund earmarked for school transportation costs has not been fully funded since the 2010 fiscal year, averaging about 73% funding, and Illinois superintendents have requested that the state meet its obligations and provide an additional $93 million for 2020.[30] Rural school districts’ frustrations in securing transportation funding is just one manifestation of the difficulties they face in every interaction with the state government. But dealing with the federal government presents difficulties too, given that the formulae dictating federal support are generated by population, not necessarily by need.[31]

Federal funding is especially unreliable given that many rural counties are seeing populations decline.[32] In one remarkable case, Alexander County lost around a quarter of its population in less than 10 years.[33] The poorest county in the state in terms of median income has an estimated population of 6,315, down from 8,238 in 2010. It also has one of the lowest property tax rates in the state, at 1.170%.[34] Alexander County has two school districts, Cairo Unit School District (USD) 1 and Egyptian Community Unit School District (CUSD) 5, accounting for 836 students. Ninety-two percent of these students are low-income, where a student is “low-income” if they:

> “receive or live in households that receive public aid from SNAP > (Supplemental Nutrition Assistance Program) or TANF (Targeted > Assistance for Needy Families); are classified as homeless, migrant, > runaway, Head Start, or foster children; or live in a household where > the household income meets (USDA) guidelines to receive free or > reduced-price meals.”[35]

This value is substantially higher than the state average, which hovers around 50% with slight variations from year to year.

Based on local revenues, Cairo USD 1 is at only 70% capacity to meet expectations, and Egyptian CUSD 5 is at 64% capacity. An additional $3.6 million is necessary for these two school districts to meet their obligations. The result of Alexander County’s dearth of school funding reflects in Egyptian CUSD 5’s academic benchmarks; just 12% of the districts 448 students tested proficient on the SAT English & Language Arts (ELA) test, and an alarming 0% tested proficient on the Mathematics module (Illinois Report Card).[36] [37]

Alexander County’s school districts are also substantially segregated, which itself is not at all unusual for rural Illinois.[38] The de facto segregation that exists in Alexander County today occurred as a result of the federal government’s segregation policies under the Roosevelt administration, as well as the gross mismanagement of public funds that has plagued the county in recent years. The federal government created segregated housing projects for Alexander residents. While a civil rights lawsuit eventually forced the desegregation of these projects, in the following decade only the formerly white housing project achieved integration.[39] More recently, the Alexander County Housing Authority has been at the center of a corruption scandal involving the mismanagement of public money; the former director, James Wilson, allegedly spent nearly a million dollars from the Authority’s funds on airline travel, hotels, and meals from 2011 to 2014.[40] This episode is considerably troubling, given that the Authority allowed two of Cairo’s housing projects to decay to the point that “emergency” demolitions are now necessary, according to the Department of Housing and Urban Development.[41] The city’s black population, and the school district’s black students, will suffer the most because of this; 88% of Cairo USD 1’s students are black, and around 98% come from low income families in and around the housing projects.[42]

The situation in Johnson County, the second poorest county in the state, is roughly the same. Johnson County has six school districts, with 1,823 students between seven schools. These school districts average around 60% financial capacity to meet expectations, and in total require an additional $8.5 million to meet expectations. Johnson County students did not score as poorly on standardized tests as Alexander County students, but their performance in 2018 was generally below the state average. Vienna High School District (HSD) 133 and Goreville CUSD 1 both scored lower than the state average proficiency in mathematics, at 21% and 18% below average respectively. However, both school districts achieved proficiency in the ELA module within 1% of the state average.[43] [44] In Vienna HSD 133’s case, this appears to be attributable to a comprehensive English curriculum beginning in 8^th^ grade, including the equivalent of 100-level university courses.[45]

The disparity in academic achievement between wealthy and poor counties in Illinois is also apparent in urban areas. Kankakee County, the poorest county in Illinois in terms of median income with a population over 100,000 is also largely unable to meet funding requirements using property tax revenues. Kankakee has a property tax rate of around 2.24%, but an overall median home value of $124,000 (just $72,000 in Kankakee City itself).[46] [47] It should be noted that property tax rates in Kankakee city are more than twice the county average, at 5.9%.[48] The two largest unit school districts in the county, Kankakee School District (SD) 111 and Herscher CUSD 2, with 5,165 and 1,718 students respectively, require a combined total of $33 million in external funding to meet expectations. Kankakee SD 111 is at just 59% capacity to meet expectations, and Herscher CUSD 2 is at 77% capacity. A majority of these nearly 7,000 students come from low-income households — 57%, as of 2017. Herscher CUSD 2 students fared considerably better on the SAT than Kankakee SD 111 students, with an ELA proficiency rate of 38% and a Mathematics proficiency rate of 44%. These figures exceed the state average by several percentage points, a fact that appears to be attributable to Herscher CUSD 2’s freedom to set curriculum, due to their significant cash-on-hand reserve and ability to deficit spend.[49] [50] Just 13% of Kankakee SD 111 students achieved proficiency in ELA, and only 8% achieved proficiency in Mathematics.[51]

FIGURE 1.3

{width=”6.5in” height=”5.041666666666667in”}

> Fig 1.3 displays a comparison of both demographics and resources > between the state of Illinois and the School District of Kankakee SD > 111. With regard to demographics, school districts see higher numbers > in all categories compared to the state of Illinois. With regard to > resources, the school district sees a 0.1% difference over the state > of Illinois in property tax rate, and the state of Illinois sees > $4,352 over the school district in resources actually derived from > property taxes.[52]

Figures from Alexander, Johnson, and Kankakee counties paint the same picture: The property tax-funded education system operating in Illinois is insufficient in areas where a significant proportion of the population come from low-income households. This insufficiency is especially visible in rural regions, where the Illinois government has been delinquent in providing equitable funding for externalities like transportation. First and foremost, the districts themselves lack the financial resources to fund themselves, as evidenced by the significant shortfalls in local property tax revenue. Bureaucratic inefficiencies in Springfield have compounded this problem, and the federal government has not taken significant enough steps to pick up the slack.

VI. Necessary Changes for Illinois

Despite these discouraging numbers, there are possibilities for changing the way schools are funded. Although the state of Illinois’s public school funding methods have been generally regressive, several policy changes have been suggested in an attempt to find more equitable solutions.

Figure 2

{width=”6.5in” height=”4.013888888888889in”}

> Figure 2 illustrates a pseudo-logarithmic relationship between cash on > hand and total financial health as measured by an aggregate of > indices. In general, a school district’s financial health (determined > by its Financial Profile Designation, a score between 0 and 4 that > indicates a given districts financial solvency) can be taken as > representative of the material conditions within school districts. > Figure 2 demonstrates that districts gain significant utility from a > modest reserve of cash on hand, but experience diminishing returns as > that amount increases.[53]

One option to explore moving forward is the implementation of a selective reinvestment program, using excess school funding generated from local property taxes. Essentially, such a system would cap expenditure for every school district at the state-determined adequacy target, and distribute the surplus to underfunded districts within Illinois. This policy is based on the relationship between cash on hand and overall financial solvency noted in fig. 2.

The Illinois Board of Education categorizes every district in the state into one of four financial categories: Recognition, Review, Early Warning, and Watch. These categories represent, broadly speaking, the financial stability of a school district. The Board of Education categorizes school districts by examining their finances, considering both their immediate situation and their ability to remain solvent going forward. Every school district is assigned a value from 0 to 4, with 4 being the most stable. Districts that score over 3.54 are assigned the the most favorable Financial Profile Designation, Financial Recognition.

The goal of any substantial program of funding reform should be to raise every district in Illinois into the Financial Recognition category. As we have discussed in previous sections, there is a strong relationship between the financial makeup of a district and its students educational success. The financial welfare of a district is the determining factor in the material conditions of educational environments; well funded schools will have access to school supplies, up-to-date textbooks, and the supplementary materials necessary for students to succeed.

Fig. 2 indicates that cash reserves most significantly impact the Financial Profile Designation of districts with less than $25 million. To clarify, we observe that an increase of the cash reserve available to a school with very little money is dramatically more beneficial than that same increase would be to a school that already maintains substantial reserves. Selective reimbursement would involve reinvesting taxes from districts with significant cash reserves into poorer districts. Such a policy would disproportionately benefit poorer districts, at a relatively insignificant cost to wealthier districts.

One criticism of selective reinvestment is that it might be susceptible to regulatory capture. It is possible that such a system would incentivise wealthier districts to avoid overshooting their district adequacy targets by keeping property taxes low. This kind of interference is unlikely to be significant, however, given the fact that Illinois townships fund other kinds of public works from property taxes; any attempt to stem the flow of money to other districts by lowering property taxes would harm every public service.

Efforts to increase funding have been made by the current governor, J.B. Pritzker, and the former governor, Bruce Rauner. In 2017, under Governor Rauner, the Illinois legislature passed a bipartisan bill to amend the school code which is an important first step.[54]Unfortunately, the Illinois budget is not in a position to fund many increases and will not have the ability to do so until approximately 2021.[55] Pritzker has proposed an increase of at least $350 million but the amount still falls short of what is needed to meet adequacy targets. Approximately 89 percent of the funding would go to school districts that are at or below 64 percent of the adequacy target.[56] While the goal is far from met, the current governor has stated that education is one of his top priorities and that he will increase funding for public education.


  1. Illinois Report Card, Illinois Report Card, https://www.illinoisreportcard.com (last visited Apr 12, 2019). ↩︎

  2. Id. ↩︎

  3. San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973). John F. Watson, The Cause, Effect and Constitutional Consequence of Unequal Funding: Public Education in Illinois, 26 J. Marshall L. Rev. 399 (1993). ↩︎

  4. San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973). ↩︎

  5. Serrano v. Priest, 18 Cal. 3d. ↩︎

  6. Carmel Martin et al., A Quality Approach to School Funding Center for American Progress (2018), https://www.americanprogress.org/issues/education-k-12/reports/2018/11/13/460397/quality-approach-school-funding (last visited Apr 2, 2019). ↩︎

  7. John F. Watson, The Cause, Effect and Constitutional Consequence of Unequal Funding: Public Education in Illinois, 26 J. Marshall L. Rev. 399 (1993). ↩︎

  8. Id. ↩︎

  9. An Overview of Property Tax, An Overview of Property Tax, http://www.revenue.state.il.us/publications/pios/pio-16.pdf (last visited Apr 12, 2019). ↩︎

  10. Id. at 21 ↩︎

  11. Id. ↩︎

  12. Id. at 50 ↩︎

  13. Id. at 51 ↩︎

  14. Id. at 50-51 ↩︎

  15. Illinois Report Card, State Snapshot: District Finances. ↩︎

  16. An Overview of Property Tax, An Overview of Property Tax, http://www.revenue.state.il.us/publications/pios/pio-16.pdf (last visited Apr 12, 2019). ↩︎

  17. Ary Amerikaner, Funding Gaps 2018 The Education Trust, https://edtrust.org/resource/funding-gaps-2018/ (last visited Apr 12, 2019). ↩︎

  18. In Most States, Poorest School Districts Get Less Funding, U.S. News & World Report, https://www.usnews.com/news/best-states/articles/2018-02-27/in-most-states-poorest-school-districts-get-less-funding (last visited Apr 12, 2019). ↩︎

  19. Vincent Caruso, Study: Illinois home to highest overall tax burden in the nation Illinois Policy (2018), https://www.illinoispolicy.org/study-illinois-home-to-highest-overall-tax-burden-in-the-nation/ (last visited Mar 30, 2019). ↩︎

  20. Joanne Cleaver, You know Illinois’ property taxes are sky-high. But the calculation process might surprise you. chicagotribune.com (2018), https://www.chicagotribune.com/classified/realestate/ct-re-0408-property-taxes-primer-20180402-story.html (last visited Mar 30, 2019). ↩︎

  21. Illinois Population 2019, Illinois Population 2019 (Demographics, Maps, Graphs), http://worldpopulationreview.com/states/illinois-population/ (last visited Apr 2, 2019). ↩︎

  22. Dan Lambert, 11 Chicago suburbs make list of 100 richest towns chicagotribune.com (2017), https://www.chicagotribune.com/suburbs/winnetka/news/ct-wtk-richest-towns-us-chicago-tl-0406-20170328-story.html (last visited Apr 2, 2019). ↩︎

  23. Illinois Property Tax Calculator, SmartAsset, https://smartasset.com/taxes/illinois-property-tax-calculator#eHVUoxpSbm (last visited Apr 2, 2019). ↩︎

  24. Equity Dashboard, Advance Illinois, http://www.advanceillinois.org/datadesk-equitydashboard/?fbclid=IwAR1Hx8H3sWF8GCSLAzvIL842K4U5AOoAV_77LYmaj5vSR-objx3lYk9NMb8 (last visited Apr 22, 2019). ↩︎

  25. Id. ↩︎

  26. Equity Dashboard, supra note 24 ↩︎

  27. Illinois School Funding Reform Commission, Report to the General Assembly and Governor Rauner, 6 (2017). ↩︎

  28. Federal Highway Administration, National Household Travel Survey Brief, 1 (2008). ↩︎

  29. Illinois School Funding Reform Commission, Report to the General Assembly and Governor Rauner, 6 (2017). ↩︎

  30. Illinois State Board of Education, Fiscal Year 2020 Budget Recommendation — Funding a Civil Right: Quality Education for All, (Springfield: Illinois State Board of Education, 2019), 11. ↩︎

  31. Office of State Support, Improving Basic Programs Operated by Local Educational Agencies (Title I, Part A), (Washington: United States Department of Education). ↩︎

  32. Norman Walzer, and Brian Harger, “Illinois Issues: The Rural Exodus,” NPR Illinois, August 10, 2017, http://www.nprillinois.org/post/illinois-issues-rural-exodus#stream/0. ↩︎

  33. United States Census Bureau, 2010 Census of Population, (Washington: United States Department of Commerce). ↩︎

  34. Smartasset, “Illinois Property Tax Calculator,” Smartasset, last updated 2019, https://smartasset.com/taxes/illinois-property-tax-calculator. ↩︎

  35. Illinois Report Card, Low Income Students, (Springfield: Illinois State Board of Education, 2018). ↩︎

  36. Illinois Report Card, Cairo USD 1. ↩︎

  37. Illinois Report Card, Egyptian CUSD 5. ↩︎

  38. J. Brian Charles, Daniel C. Vock, and Mike Maciag, “Still Apart After All These Years,” Governing, January 23, 2019, http://www.governing.com/topics/education/gov-segregation-schools.html ↩︎

  39. Michael P. Seng, “The Cairo Experience: Civil Rights Litigation in a Racial Powder Keg,” Oregon Law Review, Volume 61, no. 285 (1981): 20 ↩︎

  40. Molly Parker, “Living large on the public dime,” The Southern, September 20, 2015, https://thesouthern.com/ ­news/local/living-large-on-the-public-dime/article_820dffcd-5a92-5e9b-8a7a-d5671034ca5a.html ↩︎

  41. Molly Parker, “HUD announces $6 million grant to demolish Elmwood and McBride in Cairo,” The Southern, September 20, 2018, ↩︎

  42. Illinois Report Card, Cairo USD 1. ↩︎

  43. Illinois Report Card, Vienna HSD 133. ↩︎

  44. Illinois Report Card, Goreville CUD 1. ↩︎

  45. Vienna High School, Vienna High School’s Course/Curriculum Alignment and Sequence Map, (Vienna: Vienna High School), 2018. ↩︎

  46. Smartasset, “Illinois Property Tax Calculator” ↩︎

  47. Zillow, “Kankakee County Home Prices and Values,” Zillow, last updated 2019, https://www.zillow.com/kankakee-county-il/home-values/. ↩︎

  48. David Guiliani, “Tax burden highest in Kankakee,” Daily Journal, June 2, 2018, https://www.daily-journal.com/news/local/tax-burden-highest-in-kankakee/article_1e2cb0e0-5f7b-11e8-8a39-87a290da5c95.html. ↩︎

  49. Illinois report Card, Herscher CUSD 2 ↩︎

  50. John Dykstra, “As funding slows, Herscher school district looks to borrow $1M,” Daily Journal, November 15, 2016, https://www.daily-journal.com/news/local/as-funding-slows-herscher-school-district-looks-to-borrow-m/article_37b42725-013b-5098-baf3-1ab32bb056d3.html ↩︎

  51. Illinois Report Card, Kankakee SD 111 ↩︎

  52. Equity Dashboard, supra note 24 ↩︎

  53. AFR Profile List(2018), http://webprod1.isbe.net/finprofile/FinProfileList.aspx?yr=2018&type=1&page=dnld (last visited May 13, 2019). ↩︎

  54. Public Act 100-0582, HB5812 Enrolled. ↩︎

  55. Jerry Nowicki, Budget analysts: Evidence-based school funding model working, needs more funding (2019), https://www.chillicothetimesbulletin.com/news/20190327/budget-analysts-evidence-based-school-funding-model-working-needs-more-funding (last visited Apr 12, 2019). ↩︎

  56. Id. ↩︎