A.C. v. Raimondo, 494 F.Supp.3d 170

Background:

Putative class action by Rhode Island public-school students (grades 7–12 plus one preschool plaintiff) alleging the State fails to provide adequate civics education, injuring their ability to function as civic participants.
Plaintiffs sued State education officials seeking declaratory and injunctive relief to require meaningful civics instruction statewide.
Defendants moved to dismiss raising Rule 19 joinder, Article III standing (redressability), and political-question defenses; separate motions by Education and Government defendants.
The court rejected joinder and political-question defenses, found plaintiffs had standing for most claims but not for Count IV (jury-related Sixth/Seventh Amendment and Jury Selection Act claims).
On the merits the court held there is no fundamental right to civics education under substantive due process (following Rodriguez and Glucksberg framework) and applied rational-basis review to equal-protection claims, leading to dismissal of the complaint.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 19 joinder: must local LEAs be joined?	Claim targets statewide policymaking; suit properly against State defendants.	Local school committees/LEAs are the responsible parties and thus necessary.	Joinder not required; plaintiffs target State-level policy makers.
Standing / redressability	Plaintiffs allege concrete civics-education harms and that a court order would redress them.	Relief is speculative and not likely to redress injuries.	Standing established for most claims; Count IV (jury-service claim) lacks a present injury and fails standing.
Political-question doctrine	Claims are judicially manageable and seek enforcement of constitutional rights.	Curriculum and education policy are committed to political branches; nonjusticiable.	Not a political question under Baker factors; case is justiciable.
Substantive due process: is civics education a fundamental right?	A quantum of education (civics/literacy) is necessary for ordered liberty and political participation.	Rodriguez and precedent show education is not a federally protected fundamental right.	No fundamental right to civics education; Glucksberg framework requires deep historical roots—plaintiffs' theory fails.
Equal protection: is heightened scrutiny required?	Lack of civics education burdens fundamental rights and disproportionately harms marginalized groups.	No suspect class, no fundamental right; funding/local-control choices are rationally related to legitimate ends.	No suspect class or fundamental right; rational-basis review applies and defendants’ regime survives.

Key Cases Cited

San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973) (education not a federal constitutional right; left open extreme total-deprivation claims)
Brown v. Board of Education, 347 U.S. 483 (1954) (racial segregation in public education unconstitutional; education important to citizenship)
Gary B. v. Whitmer, 957 F.3d 616 (6th Cir. 2020) (panel opinion arguing for a federal right to basic literacy; later vacated en banc)
Washington v. Glucksberg, 521 U.S. 702 (1997) (standard for identifying fundamental rights under substantive due process)
Plyler v. Doe, 457 U.S. 202 (1982) (denial of education to a discrete class warranted heightened scrutiny in its unique context)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing and redressability requirements)
Baker v. Carr, 369 U.S. 186 (1962) (political-question doctrine factors)
Obergefell v. Hodges, 576 U.S. 644 (2015) (discussion of ordered liberty in substantive-due-process analysis)
Kadrmas v. Dickinson Pub. Sch., 487 U.S. 450 (1988) (rejecting poverty as a suspect classification for equal-protection scrutiny)