  For a planar simplicial complex Delta contained in R^2, Schumaker proved that
a lower bound on the dimension of the space C^r_k(Delta) of planar splines of
smoothness r and polynomial degree at most k on Delta is given by a polynomial
P_Delta(r,k), and Alfeld-Schumaker showed this polynomial gives the correct
dimension when k >= 4r+1. Examples due to Morgan-Scott, Tohaneanu, and Yuan
show that the equality dim C^r_k(Delta) = P_Delta(r,k) can fail when k = 2r or
2r+1. We prove that the equality dim C^r_k(Delta)= P_Delta(r,k) cannot hold in
general for k <= (22r+7)/10.
