Did Serrano Cause Proposition 13?**

poor communities to generate the same tax revenues for a given local rate (Coons, Proposition 13 gutted California's proPClune and Sugarman, 1970). In an aterty tax system in 1978. Most people think tempt to comply with the coures ruling that the tax-revolt initiative was caused by the state legislature adopted a new school' excessivegovernment spending and rising aid formula that added funds to a pretax burdens on homeowners. I argue that vious program so that poor districts got the California Supreme Court's landmark proportionately more money.The state also decision, Serrano v. Priest (1971), c ' r'Pimposed revenue limits on local districts pled the Tiebout system by divorcing local in 1972 with the intention of holding the property wealth from school spending. wealthy ones down by not allowing them Serrano thus converted most property taxes to adjust asrapidly for inflation. Districts into a deadweight loss. Voters responded could, however, override the limits by loby rejecting the property tax, shifting the cal referenda, and about forty percent of school finance burden to the state. My ex580 override referenda succeeded (Dynarplanation supports the median voter model ski et al. 1989, p. 252). in contrast to Leviathan theories of state In a subsequent decision (Serrano I]), and local government. the California Supreme Court concluded that the revised formula did not go far 1. Serrano and Proposition 13 Are enough. The court instead required the Related Events. legislature to assure that state plus local spending, excluding a few categories such N August 30, 1971, the California as aid to handicapped students, should OSupreme Court ruled in Serrano v. vary by no more than $100 per pupil across Priest (96 Cal. Rptr. 601) that reliance on districts (Serrano v. Priest, 135 Cal. Rptr. local property taxes to finance public 345 [Dec. 30, 19761). 'Me court did not schools was unconstitutional because of prescribe the $100 range as the sole remthe wide disparities in taxable property edy, but it became the litmus for compliamong school districts. Reliance on local ance (Post 1979, p. 384), and, as the judge resources was held to violate the equal in Serrano 111(226 Cal. Rptr. 584 [19861) protection clause of the California and U.S. noted, other acceptable remedies did not Constitutions because it made children's differ much from this standard. The soeducational opportunities dependent on the phisticated district power equalization wealth of the community in which they approach was discarded in favor of the were located. This landmark decision preeasily-monitored $100 standard, though saged similar rulings in several other the court did permit the state to index the states. Attempts to make it a federal is$100 for inflation. A law signed by the sue were not successful, but the U.S. Sugovernor in September 1977, which was preme Court did not prohibit the state to take effect July 1, 1978, attempted to courts from exercising this expansive view comply with the $100 range. It placed more of their own constitutions (San Antonio severe limits on wealthy districts' spendIndependent School District v. Rodriguez, ing, and it took some of the property taxes 411 U.S. 1 [19731). raised in those districts and transferred The California court in 1971 declined to them to the state for distribution to the order a specific remedy for reliance on lopoorer districts (AB 65, Chap. 894). cal property taxes, though it suggested, In June, 1978, on the eve of the impleamong other approaches, district power mentation of the legislature's response to equalization, which would allow rich and Serrano II, California voters endorsed by *Dartmouth College, Hanover, NH 03755. a 2-1 margin a statewide ballot initiative