Citizens for Strong Schools, Inc. v. Florida State Board of Education, 16-2862

Background

Appellants (Citizens for Strong Schools, parents and students) sued Florida officials alleging statewide violations of Article IX, §1(a) — that the State failed to provide a "uniform, efficient ... and high quality system of free public schools" and adequate funding/oversight.
Claims challenged adequacy, uniformity, efficiency, and whether students can obtain a "high quality" education; plaintiffs also attacked two school-choice programs (Florida Tax Credit and McKay scholarship).
After extensive discovery and a four-week bench trial with 40+ witnesses and 5,300+ exhibits, the trial court found the claims raised political questions lacking judicially manageable standards and alternatively found the State’s actions rationally related to constitutional duties.
The trial court dismissed the Tax Credit challenge for lack of standing; the uniformity challenge on appeal focused on the McKay Scholarship (specialized program for students with disabilities, ~30,000 pupils).
The district court affirmed: (1) adequacy/efficiency/"high quality" claims nonjusticiable under the political-question doctrine and Florida’s strict separation of powers; (2) McKay does not violate uniformity because it is limited, benefits disabled students, and does not materially affect the statewide system.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Justiciability — are adequacy/efficiency/high-quality claims judicially reviewable?	The Constitution imposes a "paramount duty"; courts can and should assess compliance with Article IX, §1(a).	The constitutional terms lack judicially manageable standards and raise political questions committed to the legislature/executive.	Nonjusticiable: terms lack discoverable standards; political-question doctrine and strict separation of powers bar judicial review.
Standard of review / burden of proof for Article IX claims	A lower, more permissive standard should apply to assess constitutional compliance.	Even if justiciable, plaintiffs must prove violation; but defendants argued the issue is nonjusticiable.	Court declined to adopt a different standard because claims were held nonjusticiable; trial court’s alternative rational-basis-like finding left intact.
Uniformity — do scholarship programs (McKay) violate requirement of a uniform system?	McKay diverts public funds to private schools not subject to same public-school requirements, undermining uniformity.	McKay is a specialized program for disabled students, small in scale, and improves access and system quality; thus not a uniformity violation.	Held: McKay does not violate Article IX, §1(a); program is limited, benefits disabled students, and lacks a material effect on statewide system.
Standing to challenge Florida Tax Credit Scholarship Program	Plaintiffs challenged both programs.	Defendants argued plaintiffs lacked taxpayer standing to attack the Tax Credit Program.	Tax Credit challenge dismissed for lack of standing (controlled by McCall v. Scott); not pursued on appeal.

Key Cases Cited

Baker v. Carr, 369 U.S. 186 (1962) (establishes political-question factors, including lack of judicially manageable standards and textual commitment to political branches)
Coalition for Adequacy & Fairness in School Funding, Inc. v. Chiles, 680 So. 2d 400 (Fla. 1996) (Florida Supreme Court: "adequacy" claims may present nonjusticiable political questions absent manageable standards)
Haridopolos v. Citizens for Strong Schools, Inc., 81 So. 3d 465 (Fla. 1st DCA 2011) (en banc) (certified question on whether Article IX, §1(a) supplies judicially ascertainable standards)
Bush v. Holmes, 919 So. 2d 392 (Fla. 2006) (interprets "uniform" in Article IX and limits applicability of Holmes to structurally different programs)
State v. Cotton, 769 So. 2d 345 (Fla. 2000) (discusses Florida’s strict separation of powers doctrine)