Clint Independent School District v. Sonia Herrera Marquez, Claudia Garcia, and Alicia Gomez, for and on the Behalf of Their Minor Children
487 S.W.3d 538
| Tex. | 2016Background
- Parents of students in Clint Independent School District sued the district alleging intra-district funding allocations favor some campuses (Clint) over others (Montana Vista, Horizon City), harming higher-need students and violating the Texas Constitution (Art. I §3 equality; Art. VII §1 general diffusion of knowledge).
- Parents sought injunctive and declaratory relief requiring funding be allocated "appropriately weighted according to the state funding formula."
- Clint ISD filed a plea to the jurisdiction asserting governmental immunity, political-question doctrine, and that the parents failed to exhaust administrative remedies under Tex. Educ. Code §7.057.
- The trial court dismissed for failure to exhaust administrative remedies; the court of appeals reversed, holding constitutional claims need not be administratively exhausted.
- The Texas Supreme Court granted review to decide whether §7.057 requires exhaustion when constitutional claims arise from alleged violations of the Education Code and concluded administrative exhaustion is required here.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §7.057 requires exhaustion before suing over district funding allegedly violating constitutional education rights | Parents: Their claims are purely constitutional and thus not covered by §7.057 | District: Claims arise from violations of Education Code (Title 2) so §7.057 applies and exhaustion is required | Held: §7.057 applies because the claimed constitutional injury necessarily arises from alleged violations of the "school laws" in Title 2; exhaustion required |
| Whether constitutional claims are categorically exempt from exhaustion | Parents: Constitutional claims are exempt; their pleading names only constitutional causes of action | District: Artful pleading cannot avoid statutory jurisdictional prerequisites; substance controls over labels | Held: No categorical exemption; where constitutional claims are "ancillary to and supportive of" alleged violations of school law, exhaustion applies |
| Applicability of §7.057(a–1) (exceptions for laws outside Titles 1–2) | Parents: Their claims are "outside" Titles 1–2 (constitutional) so (a–1) exempts them | District: Parents challenge district compliance with Title 2; (a–1) aimed at separately enforceable laws incorporated by reference (e.g., Open Meetings Act), not core Education Code duties | Held: §7.057(a–1) does not apply; parents’ claims are not outside Title 2 because they assert failures to comply with Title 2 duties |
| Whether equitable/temporary injunctive relief avoids exhaustion (irreparable harm exception) | Parents: They seek immediate relief; Commissioner cannot provide immediate injunction so they may proceed to court | District: Parents seek to change longstanding funding — not mere preservation of status quo; central merits question requires full administrative/merits process | Held: Houston Fed’n of Teachers exception inapplicable here; requested injunction would alter longstanding status quo and the central legal question must be resolved after administrative exhaustion |
Key Cases Cited
- City of Houston v. Rhule, 417 S.W.3d 440 (Tex. 2013) (explaining implied exclusive agency jurisdiction and exhaustion doctrine)
- Subaru of Am., Inc. v. David McDavid Nissan, Inc., 84 S.W.3d 212 (Tex. 2002) (agency implied exclusivity when pervasive regulatory scheme indicates exclusivity)
- Cypress–Fairbanks Indep. Sch. Dist. v. Tex. Educ. Agency, 830 S.W.2d 88 (Tex. 1992) (discussing TEA jurisdiction and noting limited McNeese/Damico federal-exhaustion exception)
- McNeese v. Board of Education, 373 U.S. 668 (U.S. 1963) (federal statutory claims under §1983 not defeated by state exhaustion rules in federal court)
- Damico v. California, 389 U.S. 416 (U.S. 1967) (exhaustion rule does not strip federal courts of jurisdiction over federal claims)
- Houston Federation of Teachers v. Houston Indep. Sch. Dist., 730 S.W.2d 644 (Tex. 1987) (temporary-injunction exception to exhaustion where agency cannot provide immediate relief and irreparable harm is shown)
- Newton v. McGinnis, 146 S.W.3d 648 (Tex. 2004) (temporary injunctive relief cannot be used to resolve the central merits when the status quo is the long-standing contested practice)