Cahokia Unit School District No. 187 v. Pritzker
2021 IL 126212
Ill.2021Background
- Twenty-two Illinois school districts sued seeking a declaratory judgment that the State and Governor must provide funding necessary to meet Illinois learning standards and adequacy targets set by the Evidence‑Based Funding for Student Success Act (Funding Act). Plaintiffs sought specific dollar judgments, a court-ordered funding schedule, and retention of jurisdiction to enforce payments.
- Plaintiffs alleged systemic underfunding: their districts’ per‑pupil revenues and instructional spending fall well below state averages and correlate with lower student performance on standards-based assessments; State Board estimated billions more needed to meet targets.
- The trial court dismissed the complaint under sections 2‑615 and 2‑619 (failure to state a claim and affirmative defenses), relying on sovereign immunity and precedent that educational‑quality claims are for the legislature. The appellate court affirmed; plaintiffs abandoned claims against the State and appealed only as to the Governor.
- Plaintiffs argued that modern learning standards and the Funding Act created judicially manageable benchmarks and that the Governor should be ordered to fund or propose budgets to meet those benchmarks and equal protection obligations.
- The Governor argued he lacked authority to appropriate funds, sovereign immunity and separation‑of‑powers barred relief against him, and no actual controversy existed because he could not itself grant the requested relief.
- The Illinois Supreme Court held the Governor is not a proper defendant (no actual controversy) and that courts cannot order budget appropriations or dictate the Governor’s exercise of budgetary discretion; it affirmed dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Governor a proper defendant for a declaratory judgment ordering additional state funding? | Governor can be ordered to provide funding or include amounts in his budget to achieve statutory adequacy targets. | Governor lacks authority to appropriate funds; cannot unilaterally grant relief sought. | No — Governor is not a proper party; no actual controversy exists; declaratory relief against him is improper. |
| May a court direct the Governor to include specific funding in his proposed State budget? | Court may direct Governor to act (or to include funding) as a practical means to secure relief. | Budget proposal power is constitutionally vested in Governor; directing it violates separation of powers. | No — ordering the Governor’s budget proposals would intrude on executive and legislative powers and is barred. |
| Are education‑article claims (Ill. Const. art. X, §1) judicially manageable now that learning standards and the Funding Act exist? | Learning standards and the Funding Act provide discoverable, manageable criteria to adjudicate adequacy. | Precedent holds courts lack judicially manageable standards to define/ enforce a “high quality” education; such policy is for legislature. | Court declined to adjudicate; prior precedent (Edgar, Lewis) forecloses judicial definition of constitutionally adequate education; justiciability not met here. |
| Do equal protection challenges to the funding system survive given the Funding Act? | The Funding Act reflects a shift toward statewide adequacy and equal opportunity, undermining the rational‑basis defense. | Funding structure is rationally related to legitimate state goal of balancing equality and local control. | Dismissed; appellate precedent treating funding as rationally related to local control remains controlling; claim not resolved in plaintiffs’ favor. |
Key Cases Cited
- Committee for Educational Rights v. Edgar, 174 Ill. 2d 1 (1996) (held courts cannot define or adjudicate what constitutes a "high quality" education; such determinations are legislative)
- Lewis E. v. Spagnolo, 186 Ill. 2d 198 (1999) (reaffirmed Edgar that courts lack judicially manageable standards to enforce education‑article claims)
- Illinois Press Ass'n v. Ryan, 195 Ill. 2d 63 (2001) (governor not a proper defendant where he lacks authority over the challenged legislative entity; no actual controversy)
- Saline Branch Drainage District v. Urbana‑Champaign Sanitary District, 399 Ill. 189 (1948) (dismissal where pleadings did not show an actual controversy between parties)
- Beahringer v. Page, 204 Ill. 2d 363 (2003) (sets out actual controversy/ standing requirements for declaratory relief)
- State v. American Federation of State, County & Municipal Employees, Council 31, 2016 IL 118422 (2016) (appropriation power vested exclusively in the General Assembly)