Cave Creek Unified School District v. Ducey
231 Ariz. 342
Ariz. Ct. App.2013Background
- Prop. 301 (2000) approved inflation adjustments to education funding via § 15-901.01.
- SB 1007 (2000) directed a 2% base increase or other component increases subject to voter approval.
- Voter pamphlet and legislative analysis described automatic inflation adjustments in the funding base and other components.
- In 2010 HB 2008 funded only the transportation component, not the base level, raising constitutional questions under the Voter Protection Act (VPA).
- Appellants—school districts and individuals—sued to enforce § 15-901.01 as a referendum-protected obligation requiring annual increases to all components.
- Court reviews de novo: statutory interpretation, voters’ intent, and VPA consistency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 15-901.01 imposes a mandatory obligation to fund inflation adjustments. | Appellants argue Prop. 301 mandates annual increases in all components. | State/Legislators contend the text is not a self-executing mandate binding future legislatures. | Yes; § 15-901.01 is mandatory for all components. |
| Whether the statute requires increases for all components or allows a selective approach. | Or should be read as and (all components) given legislative history. | Or should be read as an option (at least one component) under plain text. | Or must be read as and (all components) to honor voters’ intent. |
| Whether applying VPA limits on amendments/repeals affects interpretation of § 15-901.01. | VPA protects voter-approved measures from legislative amendments that undermine them. | Legislature cannot be bound beyond what the text allows or past decisions. | VPA applies; legislature must implement § 15-901.01 consistent with voters’ intent. |
| Extent of the Legislature’s obligation and potential voters’ intended scope. | Evidence shows legislature intended full inflation funding of all components. | Legislature may exercise discretion; history is not controlling. | Legislature must fund all components annually per § 15-901.01 to honor Prop. 301. |
Key Cases Cited
- Ariz. Early Childhood Dev. & Health Bd. v. Brewer, 221 Ariz. 467 (2009) (VPA limits on altering voter-approved measures; intent of electorate emphasized)
- Foglio v. Brain, 229 Ariz. 12 (App. 2011) (mandatory directives in funding provisions interpreted as binding)
- Hernandez v. Frohmiller, 68 Ariz. 242 (1949) (initiative provisions; separation of powers concerns; legislature cannot compel action)
- Estrada, 201 Ariz. 247 (2001) (interpretation beyond plain language when contrary to legislative intent)
- Willis v. United States, 719 F.2d 608 (2d Cir. 1983) (textual choice between 'or' and 'and' can reflect intent to require multiple actions)