Recently, the Minnesota Supreme Court reversed the dismissal of a lawsuit arguing that the State has a duty under the Minnesota Constitution to provide an adequate education, and that, due to substantially segregated student populations, the State is failing to fulfill this duty. Although the merits have not yet been reached, this decision opens the door for judicial review of the system of education established by the Legislature, which could have significant impacts down the line.
In Cruz-Guzman v. State, the plaintiffs sought to bring a class action on behalf of children enrolled in Minneapolis Public Schools and St. Paul Public Schools. Their complaint presented data that alleged a high degree of segregation based on race and socioeconomic status, resulting in worse academic outcomes in schools that are “disproportionately comprised of students of color and students living in poverty, as compared with a number of neighboring and surrounding schools and districts.” The complaint attributed this segregation to a number of factors, including boundary decisions for school districts and school attendance areas, and the formation of charter schools that are exempted from desegregation plans.
The complaint alleged that, as a result, the State has violated the Education Clause of the Minnesota Constitution, which says that “[t]he stability of a republican form of government depending mainly upon the intelligence of the people, it is the duty of the legislature to establish a general and uniform system of public schools.” The complaint also raised claims under the Equal Protection and Due Process Clauses.
The Minnesota Court of Appeals dismissed the case, holding that the claims represented political questions about educational quality that were appropriately left to the Legislature, not the courts. The Supreme Court, however, in a 4-2 decision authored by Justice Hudson, reversed and revived the lawsuit. The Court held that, although specific educational policy decisions must be left to the Legislature, the judiciary still has a role in deciding whether the Legislature has satisfied its constitutional obligation under the Education Clause.
The Court also held that there is an implied requirement of adequacy in the Education Clause, noting that the “framers could not have intended for the Legislature to create a system of schools that was ‘general and uniform’ and ‘thorough and efficient’ but that produced a wholly inadequate education.” As a result, some level of qualitative assessment is necessary to determine whether the state is meeting this obligation. “We cannot,” the Court held, “fulfill our duty to adjudicate claims of constitutional violations by unquestioningly accepting that whatever the Legislature has chosen to do fulfills the Legislature’s duty to provide an adequate education. If the Legislature’s actions do not meet a baseline level, they will not provide an adequate education.”
This decision is not based on the merits of the case, so the Court did not elaborate, at this point, on what that baseline level might look like. But should the plaintiffs ultimately prevail on their claim that Minnesota schools are too segregated to satisfy the constitutional education requirements, the Legislature may be forced to make changes, which could have consequential effects on districts and charter schools. Even if this case is not successful, challenges that claim the State is failing to ensure an adequate education for other reasons are now viable. One such case, arguing that the state’s teacher-tenure laws inhibit an adequate education, is currently pending before the Court of Appeals. The success rate of any these challenges is difficult to predict, but the door has been opened, which could result in some intriguing legal developments in the months and years to come.
This article is intended to provide general information with commentary. It should not be relied on as legal advice. If required, legal advice regarding this topic should be obtained from district legal counsel.
Adam Wattenbarger is an education law attorney with the law firm of Kennedy & Graven, Chartered. For more information, please contact him at (612) 337-9306 or www.kennedy-graven.com.
© Adam C. Wattenbarger (2018). Used by permission.