Cahokia Unit School District No. 187 v. Pritzker
156 N.E.3d 510
Ill. App. Ct.2020Background
- Plaintiffs: 22 Illinois school districts alleging state funding shortfalls prevent them from meeting the Illinois Learning Standards and related assessments (including PARCC).
- ISBE and statute (Evidence-Based Funding for Student Success Act, 2017) define Learning Standards and an adequacy-based funding formula; ISBE calculated a multi-billion dollar funding gap (plaintiffs alleged an additional $7.2 billion required).
- Plaintiffs sued the Governor and the State seeking declaratory relief and a schedule/order to provide funding necessary to meet the Learning Standards and adequacy targets (relief tied to ISBE’s adequacy calculations).
- Defendants moved to dismiss under sections 2-615/2-619, asserting sovereign immunity, lack of standing to assert students’ rights, and failure to state constitutional claims; the trial court dismissed the complaint with prejudice.
- The Fifth District affirmed, holding (1) the State is immune and not a proper defendant in circuit court; (2) precedent (Edgar and Lewis) bars judicial enforcement of the quality-education clause and the equal-protection challenge to the funding system.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Whether the State of Illinois may be sued in circuit court | State is a proper defendant for constitutional relief | State enjoys sovereign immunity; Court of Claims is exclusive forum | Dismissed as to the State: sovereign immunity bars suit in circuit court |
| 2. Whether the Governor may be sued (officer-suit exception) | Officer-suit exception permits suing Governor in official capacity to enforce constitutional duties | Governor cannot effectuate requested remedy; may be improper party | Court assumed arguendo but analyzed merits; did not reach broad permissibility question—claims dismissed on merits |
| 3. Whether the Quality Education Clause (Art. X, §1) is judicially enforceable here | ISBE standards and Funding Act give measurable definition of "high quality" education; courts can enforce Governor’s duty to fund adequacy | Precedent holds education-quality is nonjusticiable; courts must defer to legislature/policy makers | Dismissed: bound by Committee for Educational Rights v. Edgar and Lewis v. Spagnolo; quality-education claim nonjusticiable |
| 4. Whether disparities in funding violate Equal Protection (Art. I, §2) | Funding Act and Learning Standards show legislative shift away from local control; current disparities therefore lack rational basis | Prior precedent upholds funding scheme as rationally related to legitimate goal (local control) | Dismissed: equal-protection challenge barred by Edgar; review under rational-basis and precedent controls |
Key Cases Cited
- Committee for Educational Rights v. Edgar, 174 Ill. 2d 1 (1996) (held courts may not adjudicate a claim that the State failed to provide a "high quality" education under the constitution)
- Lewis v. Spagnolo, 186 Ill. 2d 198 (1999) (reaffirmed Edgar: quality-education claims fail)
- Township of Jubilee v. State of Illinois, 2011 IL 111447 (2011) (explains State Lawsuit Immunity Act and Court of Claims as exclusive forum for claims against the State)
- Illinois Press Ass'n v. Ryan, 195 Ill. 2d 63 (2001) (discusses when the governor is an improper party because he cannot effectuate relief)
- Yakich v. Aulds, 2019 IL 123667 (2019) (reiterates that lower courts are bound by Illinois Supreme Court precedent and may not overrule it)