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In school finance lawsuits plaintiffs often claim that pay levels are not sufficient to recruit teachers who can deliver constitutionally-mandated levels of educational services. In this paper I consider several ways in which one might bring economic theory and data to bear on that question. I conclude that at present, and at least for the near term, education research cannot prescribe an "adequate" level of school spending on teachers, whether in the form of pay, benefits, or professional training, that can reliability predict a target level of student performance. If courts are predisposed to intervene in this matter, a more reasonable standard for "adequacy" is whether available revenues, when spent in an efficient manner, are sufficient to staff classrooms with appropriately-certified teachers in a flexible licensing regime that satisfies both state and federal teacher quality standards. (Contains 6 figures, 7 tables and 15 endnotes.)