In New Jersey's Abbott v. Burke litigation, 28 'special need' districts were allowed to spend as much as the highest-spending district—reaching roughly $19,000 per student versus under $10,000 elsewhere—and after 35 years of court involvement, despite preschool, smaller classes, summer and after-school programs, there is essentially no evidence of rising student achievement attributable to funding (only a single 2007 4th-grade reading uptick).