Louisiana’s foundation formula uses a foundation level of $3,459 in fiscal 2005 adjusted for the local fiscal capacity of each district. Districts can levy up to 5 mills in property taxes, but the levy is not required for them to receive state aid. The Orleans Parish district, which includes New Orleans, can levy up to 13 mills. Louisiana also provides a second tier of aid to reward districts that make larger tax efforts. Any tax revenue that districts raise above their local share of the foundation formula is eligible for reward funding, but the money is limited to 33 percent of the total base-foundation amount. The reward amount equals about 40 percent of a district’s eligible revenue, equalized by the district’s local fiscal capacity. In December 2003, a group of parents, taxpayers, and local school boards filed a lawsuit against the Louisiana Board of Elementary and Secondary Education, Jones v. BESE, alleging that the education finance system violates the state constitution by failing to provide money for school construction. The state does not have a program specifically designed to finance school construction. But districts have the authority to raise local taxes dedicated to that purpose, and the state includes those taxes in the revenue eligible for reward funding. Louisiana provides categorical aid for 13 programs, including special education, literacy initiatives, professional development, and early-childhood education.