amount provided for by the new plan is necessarily arbitrary and therefore fails to satisfy the court's orders."

The New Jersey court's order to the state legislature reflected great frustration with the compliance efforts exhibited by the state defendants to date. "The legislature is required, as interim remedial relief, to assure by the commencement of the 1997-98 school year, that per-pupil expenditures in the poor urban districts are equalized to the average per-pupil expenditure in the wealthy suburban districts." In addition, the court ordered the state to study, identify, fund, and implement the supplemental programs required to redress the disadvantages of public school children in the special needs districts. Lastly, the court required the state to "assure that all education funding, including and especially the additional funding ordered today, is spent effectively, efficiently, and in furtherance of the achievement of the core curriculum content standards."

This 1997 New Jersey decision reflects something of a blend of traditional finance equity and adequacy approaches. The court required that the state conduct a study of what it would take—in terms of educational services and resources—to provide disadvantaged children in the poorer school districts with opportunities to achieve the state's educational content and achievement standards. As an interim step to moving to that adequacy-based system, however, the court required per-pupil expenditure equality between the poorest and wealthiest districts.

In May 1998, the New Jersey Supreme Court issued what could be the last decision—at least for a few years—in the state's long-running school finance battle (Abbott v. Burke, N.J. Sup. Ct. May 1998). The court noted that "this decision should be the last major judicial involvement in the long tortuous history of the State's extraordinary effort to bring a thorough and efficient education to the children in its poorest school districts." The recent decision approves a plan for funding and systemic education reform in the State of New Jersey put forward by the State Commissioner of Education after a long process of expert consultation and review.

In essence, the court ordered that the state implement the following education reforms: (1) whole school reform, namely the "Success for All" model; (2) full-day kindergarten and half-day preschool for 3- and 4-year-olds; (3) a technology, school-to-work, alternative school, accountability, and college-transition program; (4) standards that will enable individual schools to adopt additional supplemental programs and funding to support such programs where a demonstrated need is established; and (5) a comprehensive facilities plan. While these reforms were proposed in the first instance by the State Commissioner of Education, the fact that the Supreme Court has ordered that they be implemented sends a powerful message to the executive and legislative branches about the need for swift compliance.

Indeed, unlike the Kentucky Supreme Court's decision, which only articulated broad guidelines for the intended reforms, the New Jersey court has ordered