Fiscal disparities within school districts may be the next area "ripe" for litigation. Equity and adequacy litigation have largely focused on between-district fiscal disparities. Research suggests that within-district disparities may be as unfair to high poverty schools. When the school funding pie is not growing, remedying within-district fiscal disparities may be a winning strategy to support education for low-income and minority students. (Contains 1 table and 6 footnotes.)