MINNESOTA SUPREME COURT ALLOWS SCHOOL SEGREGATION LAWSUIT TO PROCEED
August 28, 2018
A Minnesota Supreme Court ruling will permit a lawsuit against the State of Minnesota to proceed without further delay. The suit alleges that the State of Minnesota has contributed to segregation in the public schools and has failed to provide students with an adequate education under the Minnesota State Constitution.
In Cruz-Guzman, et al., v. State of Minnesota, et al., Minnesota Supreme Court (A16-1265)(“Cruz-Guzman”), the Minnesota Supreme Court reversed an order of the Minnesota Court of Appeals that dismissed a class action lawsuit brought under the Education Clause of the Minnesota Constitution. The lawsuit contends that the State of Minnesota, charter schools, and school districts contributed to school segregation and “inadequate educational outcomes,” which - the lawsuit claims - run afoul of the Education Clause of the Minnesota Constitution.
The Minnesota Court of Appeals had concluded that the lawsuit “present(s) a nonjusticiable political question.” The Court of Appeals did acknowledge that segregation claims can properly be adjudicated by the courts. However, the Court determined that the lawsuit’s Constitutional attacks on educational outcomes were “rooted in a purported right to an education of a certain quality.” The Court rejected the notion that these claims could be advanced as an alleged Constitutional violation, and instead concluded that these contentions present political questions that are a job for the legislature (and not the judiciary) to address. For this reason, the Court of Appeals dismissed the lawsuit.
The Minnesota Supreme Court’s Decision
The Minnesota Supreme Court concluded that the case presented legitimate constitutional questions for the courts to resolve. The Court noted that claims alleging that the State has failed to provide students with an adequate education under the Education Clause of the Minnesota Constitution have consistently been treated as justiciable and, therefore, can be addressed by the courts. The Court reasoned that Constitutional questions have long been the province of the judiciary, adding that separation-of-powers principles do not prevent the judiciary from ruling on whether the legislature violated its duties under the Education Clause of the Minnesota Constitution.
The Court specifically recognized that the lawsuit was based on disparate educational outcomes associated with segregation based on race and socioeconomic status. The Court noted that the complaint alleged that students in the Minneapolis and St. Paul Public Schools 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 Court added that these segregated schools have significantly worse academic outcomes compared to neighboring schools and suburban school districts in areas such as graduation rates, pass rates in basic standards tests, and proficiency rates in math, science, and reading. The Court further observed that the lawsuit identified several practices by various state actors -- the Minneapolis and St. Paul Public Schools, other school districts, charter schools, and the State itself -- that contribute to school segregation and inadequate educational outcomes.
Consequently, the Court determined that claims that the state system of public education aggravates school segregation and deprives students of an adequate education present constitutional issues. The Court began by noting that the Education Clause of the Minnesota Constitution provides that “it is the duty of the legislature to establish a general and uniform system of public schools.” The Court further noted that, while it and other courts had found that previous litigants were “unable to establish that the basic (educational) system was inadequate,” the Court also determined in those same cases that the courts could at least adjudicate such claims. The Court reasoned that, while matters of educational policy are still for the legislature to decide, the Education Clause to the Minnesota Constitution constitutes a “mandate to the Legislature,” “not a grant of power.”
As a result, the Court determined that it would not interfere with or intrude upon the legislature’s policy-making authority for the courts to decide “whether the Legislature has satisfied its constitutional duty under the Education Clause” to provide a qualitatively sufficient (and equitable) educational opportunity for all Minnesota students. Consequently, the Court determined that the lawsuit could proceed and, accordingly, could challenge state practices that allegedly contribute to segregation and disparate educational outcomes in Minnesota.
Import of the Minnesota Case
It is not yet clear what influence the Minnesota case might have on other states’ courts. For example, the Education Clause of the Minnesota Constitution states that “it is the duty of the legislature to establish a general and uniform system of public schools.” In contrast, the Wisconsin Constitution states that “[t]he legislature shall provide by law for the establishment of district schools, which shall be as nearly uniform as practicable …”. Therefore -- at least when we compare the language of our own state constitution with that of Minnesota -- the Wisconsin Constitution at least may provide for a more qualified public education uniformity clause, while the Minnesota Constitution arguably requires more objective uniformity. These textual issues may influence the extent to which other state courts adopt the Minnesota Supreme Court’s reasoning when they consider lawsuits claiming that educational segregation and disparities reflect Constitutional violations.
The Minnesota case is a significant development in the ongoing debates that many states are having over equity in school funding, programming, and outcomes. To be sure, the Minnesota lawsuit has a long way to go: the Court only concluded that the lawsuit could proceed, not that the plaintiffs would actually be able to establish that Minnesota’s system of education or its education officials actually contributed to segregation and disparity in educational outcomes. Nevertheless, the fact that a state supreme court has allowed a lawsuit to proceed on grounds that its state constitution might, for example, guarantee equal distribution of educational resources, mandate specific educational results, or incorporate legal duties that must be satisfied by public education institutions is a newsworthy legal event and a development worth watching.
As a result, the Minnesota Supreme Court has our attention. At a time when public school districts are confronting serious resource challenges, any number of interested groups and citizens can be expected to at least consider seeking legal relief. The Minnesota case will certainly stimulate further thought among those groups and citizens, and we may see still more constitutional litigation over segregation, resource commitment, and educational outcomes in the public schools.
For questions regarding this article, please contact the author, Attorney Kirk D. Strang (email: firstname.lastname@example.org; telephone: 844.626.0906), or your Strang, Patteson, Renning, Lewis & Lacy, s.c., attorney.
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