Adair v. Michigan, 497 Mich. 89

More than 450 Michigan school districts and a taxpayer from each district sued under the Headlee Amendment (Const 1963, art 9, § 29), alleging the Legislature’s appropriation for CEPI/TSDL reporting mandates was constitutionally inadequate (an underfunded POUM claim).
After prior Adair litigation, the Legislature made appropriations (§ 152a and discretionary § 22b) to reimburse districts for CEPI/TSDL costs; § 22b payments were conditioned on furnishing required data.
Plaintiffs challenged the sufficiency of the 2010–2012 appropriations; the special master required plaintiffs to prove the specific dollar amount of any shortfall if some appropriation existed.
At trial plaintiffs declined to present a quantified calculation of underfunding and instead planned to attack the Legislature’s methodology for setting the appropriation; the special master granted defendants’ motion for involuntary dismissal on that ground.
The Court of Appeals reversed, adopting a standard that plaintiffs need only show the Legislature’s methodology was materially flawed; the Michigan Supreme Court granted leave and reversed the Court of Appeals, reinstating dismissal because plaintiffs refused to prove the amount of the shortfall.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether accepting conditional § 22b funds waived Headlee claim	Acceptance was not waiver; plaintiffs reserved constitutional challenge	Acceptance conditioned on compliance constitutes waiver of funding challenge	Held: No waiver; accepting conditioned funds did not waive Headlee claims
Burden when Legislature made no appropriation (per se POUM)	If no appropriation, plaintiff need only show state imposed new/increased activity	State argued plaintiffs still must quantify costs	Held (reaffirming Adair I): If no appropriation, plaintiff need not quantify increased costs; burden shifts to state to show no funding required
Burden when Legislature made some appropriation (underfunding claim)	Plaintiffs: need only show methodology was flawed; need not quantify dollar shortfall	Defendants: plaintiffs must plead and prove specific dollar amount of underfunding	Held: Where some appropriation exists, plaintiff must allege and prove the specific dollar amount of the funding shortfall (extent of harm)
Proper remedy/effect of proving methodology flaw without quantification	Plaintiffs: a showing of materially flawed methodology suffices for declaratory relief	Defendants: flawed methodology alone is insufficient; need concrete quantified shortfall to guide relief	Held: Methodology flaws alone are insufficient when some funds were appropriated; quantification required to grant effective relief

Adair v. Michigan, 486 Mich 468 (2010) (Adair I) (where no appropriation was made, plaintiff need not prove specific dollar increase; burden shifts to state)
Adair v. Michigan, 470 Mich 105 (2004) (earlier Adair decision recognizing Headlee claim viability for CEPI mandates)
Oakland County v. Michigan, 456 Mich 144 (1997) (plaintiffs must allege type and extent of harm so court can determine remedy)
46th Circuit Trial Court v. Crawford County, 476 Mich 131 (2006) (discusses heightened standards where courts compel funding for judicial operations)