NEW JERSEY COURT SYSTEM

New Jersey Court System



New Jersey Court System

After the U.S. Supreme Court refused to intervene in Robinson (1975) for the first time, the Supreme Court of New Jersey found that the state's system of school finance violated the state's education clause pertaining to the provision of a thorough and efficient system of education. According to the court, the “thorough and efficient” clause gave the state the ultimate responsibility to ensure that students receive a thorough and efficient education. Further, the Court ruled that a funding system that is reliant on local taxes was not thorough and efficient.

In Robinson, the Supreme Court of New Jersey examined two questions: whether the state or local boards had the principal responsibility for funding schools and whether urban taxpayers, who faced higher tax rates than those in other municipalities, had a right to equal taxation. At the outset of its analysis, the court cited the “thorough and efficient clause” in the state constitution: “The Legislature shall provide for the maintenance and support of a thorough and efficient system of free public schools for the instruction of all the children in the State between the ages of five and eighteen years” (Robinson, p. 716, citing New Jersey Constitution, Article VIII, Section IV, 1).

The court explained that in seeking to provide funding for public schools, the state's financing system relied heavily on local property taxes. Under this formula, the court commented that there was a wide disparity in the amount of money spent per pupil, depending on a child's district of residence, with the result that in some systems with low property wealth and high taxes, the schools were underfunded. As part of its analysis, the court acknowledged that the school funding was provided from three sources: local taxes, which provided about 67% of the total; state aid, which accounted for about 28%; and federal aid for the last 5%. As such, the court specified that the state aid did not substantially equalize the dollar amount spent per pupil.

At the same, the plaintiffs claimed that due to the financing disparity, the state offered a “thorough” education to some but not all students, as the system discriminated against property owners who were taxed at different rates for the same underlying purpose. The plaintiffs further alleged that since the language in the state constitution imposed an obligation on the state to fund public education, any tax imposed to fund education should be a “state” tax that should have been applied uniformly across the state as a whole. The court rejected this argument, responding that state functions could be delegated to the local level and funded by local taxes. If the state chose to fund education at the state level, then the court would be satisfied that property taxes would be uniformly imposed across all property in the state. Conversely, the court posited that, as was the situation in New Jersey, since the state chose to assign responsibility to the local government, all property in any given municipality ...