Education Law

Trial Court Decision in California School Finance Case

Last Spring, I reported here that a new school finance suit had been filed in California.  The suit, styled Robles-Wong v. California, presented claims founded both on inadequacy of spending systemwide and inequality of educational opportunity among California districts.  A little over a week ago, the trial court hearing the suit issued its ruling on the state's demurrer (what California calls a motion to dismiss the complaint--H/T, Silicon Valley Education Foundation for both the alert and the pdf of the court's ruling). 

The decision tracks the recent trend that I and others have identified of state courts shying away from deciding systemic educational adequacy claims.  The court dismissed the adequacy-based claims with prejudice, holding that the California Constitution does not require any particular quantity of spending.  Although the court forcefully rejected the state's non-justiciability argument, this dismissal effectively has the same effect as a dismissal for non-justiciability.  If sustained on appeal, it would mean that one cannot state a claim for educational inadequacy under the California Constitution. 

However, the court did recognize that, under the canonical Serrano v. Priest decisions, one may state an individual claim for inequality of educational opportunity, typically as a class action brought by students in a resource-deprived district.  The court dismissed the equality claims presented in the plaintiffs' complaint, which did not contain allegations of individual harm, but also granted the plaintiffs leave to amend to sharpen up their allegations.  Thus, the case is still alive, but has been trimmed down substantially (for now). 

It remains to be seen what the California appellate courts will do with the trial court's dismissals.  As I stated a few months back, watch this one--it could be a very significant decision when all is said and done. 

Full post as published by Edjurist on January 31, 2011 (boomark / email).