대치동수학 per student declined substantially also appear to have had little effect.[165] Property taxes as a primary source of funding for public education have become highly controversial, for a number of reasons. First, if a state's population and land values escalate rapidly, many longtime residents may find themselves paying property taxes much higher than anticipated. In response to this phenomenon, California's citizens passed Proposition 13 in 1978, which severely restricted the ability of the Legislature to expand the state's educational system to keep up with growth. Some states, such as Michigan, have investigated or implemented alternative schemes for funding education that may sidestep the problems of funding based mainly on property taxes by providing funding based on sales or income tax. These schemes also have failings, negatively impacting funding in a slow economy.[166] One of the biggest debates in funding public schools is funding by local taxes or state taxes. The federal government supplies around 8.5% of the public school system funds, according to a 2005 report by the National Center for Education Statistics."Revenues and Expenditures for Public Elementary and Secondary Education, Table 1". National Center for Education Statistics. Retrieved June 4, 2014. The remaining split between state and local governments averages 48.7 percent from states and 42.8 percent from local sources.[167] Rural schools struggle with funding concerns. State funding sources often favor wealthier districts. The state establishes a minimum flat amount deemed "adequate" to educate a child based on equalized assessed value of property taxes. This favors wealthier districts with a much larger tax base. This, combined with the history of slow payment in the state, leaves rural districts searching for funds. Lack of funding leads to limited resources for teachers. Resources that directly relate to funding include access to high-speed internet, online learning programs and advanced course offerings.[101] These resources can enhance a student's learning opportunities, but may not be available to everyone if a district cannot afford to offer specific programs. One study found that school districts spend less efficiently in areas in which they face little or no competition from other public schools, in large districts, and in areas in which residents are poor or less educated.[168] Some public schools are experimenting with recruiting teachers from developing countries in order to fill the teacher shortage, as U.S. citizens with college degrees are turning away from the demanding, low paid profession.[169] Judicial intervention The reliance on local funding sources has led to a long history of court challenges about how states fund their schools. These challenges have relied on interpretations of state constitutions after a U.S. Supreme Court ruling that school funding was not a matter of the U.S. Constitution (San Antonio independent school District v. Rodriguez, 411 U.S. 1 (1973)). The state court cases, beginning with the California case of Serrano v. Priest, 5 Cal.3d 584 (1971), were initially concerned with equity in funding, which was defined in terms of variations in spending across local school districts. More recently, state court cases have begun to consider what has been called 'adequacy.' These cases have questioned whether the total amount of spending was sufficient to meet state constitutional requirements. Perhaps the most famous adequacy case is Abbott v. Burke, 100 N.J. 269, 495 A.2d 376 (1985), which has involved state court supervision over several decades and has led to some of the highest spending of any U.S. districts in the so-called Abbott districts. The background and results of these cases are analyzed in a book by Eric Hanushek and Alfred Lindseth.[170] That analysis concludes that funding differences are not closely related to student outcomes and thus that the outcomes of the court cases have not led to improved policies. In McCleary v. Washington State (2012),[171] Supreme Court decision that found the state had failed to "amply"
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