OPINION ON MOTION FOR REHEARING
On motion for rehearing, plaintiff-intervenors request that we modify our opinion to overrule Love v. City of Dallas, 120 Tex. 351, 40 S.W.2d 20 (1931), or interpret that case “in a manner that would permit the [state-wide] recapture of local ad valorem revenues for purposes of equalization.” We believe Love is sound and decline to overrule or modify it. Moreover, the interpretation requested by plaintiff-in-tervenors would violate the Texas Constitution. Accordingly, we overrule the motion for rehearing.
In Love, this Court held that the City of Dallas could not be compelled to educate students who resided outside of the city’s school district. We held that article VII, section 3 of our Constitution only “contemplates that districts shall be organized and taxes levied for the education of scholastics within the districts.” 120 Tex. at 367, 40 S.W.2d at 27. Focusing on the Legislature’s power to create school districts and define their taxing authority, we noted in this opinion that, consistent with Love and contrary to the district court’s suggestion, tax base consolidation could be achieved through the creation of new school districts. We said these school districts could be organized along county or other lines and could be given the authority to generate local property tax revenue for all of the other school districts within their boundaries.
Plaintiff-intervenors now urge us to go further. They argue that all school districts are mere creatures of the state, and “in reality, all taxes raised at the local level are indeed State taxes subject to state-wide recapture for purposes of equalization.” Their position raises the question of whether the Legislature may constitutionally authorize school districts to generate and spend local taxes to enrich or supplement an efficient system.1 Because the Constitution does permit such enrichment, without equalization, local taxes cannot be considered “State taxes subject to state-wide recapture.”
Our Constitution clearly recognizes the distinction between state and local taxes, and the latter are not mere creatures of the former. The provision that “[n]o State ad valorem taxes shall be levied upon any property in this State,” Tex. Const. ART. VIII, § 1-e, prohibits the Legislature from merely recharacterizing a local property tax as a “state tax.” Article VII, section 3, however, states that “the Legislature may authorize an additional ad valorem tax to be levied and collected within all school districts heretofore formed or hereafter formed, for the further maintenance of public free schools, and for the erection and equipment of school buildings therein.” Tex. Const, art. VII, § 3 (emphasis added). These constitutional provisions mandate that local tax revenue is not subject to state-wide recapture.
*500This conclusion highlights the basic constitutional distinction between the State’s primary obligation and the local districts’ secondary contributions. The current system remains unconstitutional not because any unequalized local supplementation is employed, but because the State relies so heavily on unequalized local funding in attempting to discharge its duty to “make suitable provision for the support and maintenance of an efficient system of public free schools.” Tex. Const, art. VII, § l.2 Once the Legislature provides an efficient system in compliance with article VII, section 1, it may, so long as efficiency is maintained, authorize local school districts to supplement their educational resources if local property owners approve an additional local property tax.3
Because the relief sought by plaintiff-in-tervenors would violate the Constitution, their motion for rehearing is overruled.4 This Court will entertain no further motions for rehearing in this cause. Tex.R. App.P. 190(d).
Concurring opinions on motion for rehearing by GONZALEZ, and GAMMAGE, JJ. Concurring opinion on motion for rehearing by DOGGETT, J., joined by MAUZY and GAMMAGE, JJ.. In addition, defendants' response to plaintiff-intervenors’ motion for rehearing submits that "there continues to be considerable discussion of the meaning of the language of Edgewood I referenced in footnote 11 of Edgewood II.” Defendants therefore “urge the Court to clarify whether local enrichment violates the Constitution as interpreted by Edgewood I and Edge-wood II if the yield from local tax effort varies because of the value of a local community’s tax base.” Defendants have consistently urged the court to clarify whether unequalized local enrichment is permissible under the Constitution. Indeed, their original brief asserted by cross-point that the district court erred in "applying a standard of total equality" that mandated the elimination of all unequalized local enrichment. The motion for rehearing and defendants’ response suggest the need for greater clarity in our resolution of defendants’ argument.
. As explained in Edgewood I, the mandate of efficiency in article VII, section 1, while not requiring "a per capita distribution" or absolute equality, does prohibit the "gross inequalities” and "vast disparities” resulting from "concentrations of resources in property-rich school districts that are taxing low when property-poor districts that are taxing high cannot generate sufficient revenues to meet even minimum standards." 777 S.W.2d at 395, 396, 397. We therefore required "a direct and close correlation between a district’s tax effort and the educational resources available to it." Id. at 397.
. In advocating the amendment of article VII, section 3 to permit local supplementation, Governor Ireland explained that local districts should be "allowed to levy and collect an additional tax for the purpose of aiding the State in its efforts at giving the people an education.” Message of Governor Ireland, reprinted in Texas S.J., 18th Legislature, Regular Session, 66, 67 (January 29, 1883) (emphasis added).
. In their response to the motion for rehearing, defendant-intervenors express concern that if the Legislature fails to enact a constitutional school finance bill by April 1, 1991, our injunction will preclude the State from honoring its obligations as the guarantor of bonds issued by local school districts. These concerns are unfounded. We adopt the language of the trial court's original order in this regard, modifying the September 1, 1990, date in that portion of the order to September 1, 1991. Our deadline of April 1, 1991, for legislative action remains unchanged.