The issue of providing public education for undocumented students (children of foreign-born persons who reside and/or work in the United States without proper permission from immigration authorities) is receiving current attention for two major reasons: (1) fear that the financial burden on local taxpayers will increase in areas with increasing concentrations of undocumented students; and (2) Supreme Court declaration that Section 21.031 of Title I of the Texas Education Code, which denies reimbursement of funds to local school districts for educating undocumented children, is unconstitutional. While Texas estimates $85 million a year is spent to educate undocumented students and Los Angeles estimates annual expenditures of $415 million, the question of the actual cost of educating undocumented students continues because most states lack actual enrollment figures. The cost of developing and implementing programs for undocumented children depends upon district characteristics (numbers of students, taxable property per pupil, teacher linguistic characteristics, presence of programs for limited-English-speaking students, pupil-teacher ratios, historical enrollment patterns, status of physical facilities, and proximity to migration streams used by undocumented persons) and student characteristics (numbers, age dispersion, geographic dispersion, English fluency, prior educational experiences, length of presence in this country, and socioeconomic status). (NEC)