Clarksdale Municipal School District v. State of Mississippi
2015-CA-01227-SCT
| Miss. | Oct 19, 2017Background
- Twenty-one Mississippi public school districts sued the State seeking >$235 million, alleging the Legislature failed to "fully fund the Mississippi Adequate Education Program (MAEP)" for FY2010–2015 in violation of Miss. Code § 37-151-6.
- § 37-151-6 states: "Effective with fiscal year 2007, the Legislature shall fully fund the Mississippi Adequate Education Program."
- Districts sought declaratory, monetary, and injunctive relief; State moved for judgment on the pleadings and asserted multiple defenses (statutory interpretation, sovereign immunity, separation of powers).
- Districts also filed a summary-judgment motion; the chancellor denied Districts’ motion and granted the State’s Rule 12(c) motion.
- The chancery court held § 37-151-6 was not a mandatory, self-executing obligation requiring annual appropriations; the Supreme Court of Mississippi affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the chancery court erred in not converting State's Rule 12(c) motion to Rule 56 | Musgrove: conversion required because State attached exhibits | State: exhibits were statutes (not matters outside pleadings); Districts had filed summary judgment anyway | No error — exhibits were legal texts and parties had opportunity to present Rule 56 materials |
| Whether § 37-151-6 implements the constitutional "general law" duty in Miss. Const. art. 8, § 201 and therefore prevails over appropriations | Districts: § 37-151-6 is the general-law mandate to satisfy Art. 8 § 201 and must be enforced | State: Constitution grants Legislature discretion re: how to fulfill Art. 8 § 201; MAEP is a statutory scheme, not the only means to satisfy the Constitution | Rejected — Art. 8 § 201 imposes a general-law duty but does not require a specific dollar amount or a single statutory formula; rights claimed are statutory, not constitutional |
| Whether § 37-151-6 is a mandatory, enforceable statutory obligation to appropriate funds each year | Districts: the word "shall" makes the statutory duty mandatory and enforceable | State: statute is not self-executing; it does not bind the Governor or future Legislatures to produce enacted appropriations | Held: § 37-151-6 is not mandatory/self-executing; omission of any role for the Governor and constitutional appropriation process shows no legislative intent to create an enforceable annual appropriation obligation |
| Whether Districts are entitled to monetary relief for underfunding MAEP (separation of powers/sovereign immunity) | Districts: monetary award required to make them whole for MAEP shortfalls | State: money not appropriated; judicially ordering state to pay would violate separation of powers and appropriation rules; sovereign immunity bar | Held: Districts lack entitlement/injury because Legislature never appropriated funds and the judiciary cannot appropriate money; monetary relief unavailable |
Key Cases Cited
- Booneville Collision Repair, Inc. v. City of Booneville, 152 So. 3d 265 (Miss. 2014) (standard for motion to dismiss)
- Copiah Cnty. v. Oliver, 51 So. 3d 205 (Miss. 2011) (summary-judgment standard)
- Stewart ex rel. Womack v. City of Jackson, 804 So. 2d 1041 (Miss. 2002) (evidentiary matters to be viewed in light most favorable to nonmoving party)
- Lawson v. Honeywell Int’l, Inc., 75 So. 3d 1024 (Miss. 2011) (court's role is to determine what a statute provides)
- City of Natchez v. Sullivan, 612 So. 2d 1087 (Miss. 1992) (legislative intent guides statutory interpretation)
- Palmer v. Biloxi Reg’l Med. Ctr., 649 So. 2d 179 (Miss. 1994) (Rule 12(c) conversion to Rule 56 requires notice and opportunity to present materials)
- Colbert v. State, 39 So. 65 (Miss. 1905) (Legislature is sole repository of appropriation power)
- Smith v. Williams-Brooke Co., 71 So. 648 (Miss. 1916) (there cannot be a right without a remedy)
- Walker v. U.S. Dep’t of Housing & Urban Dev., 912 F.2d 819 (5th Cir. 1990) (courts cannot order disbursements absent legislative appropriation)
- Miller v. State, 94 So. 706 (Miss. 1923) (court may order distribution only of funds actually appropriated)