Clint Independent School District v. Sonia Herrera Marquez, Claudia Garcia, and Alicia Gomez, for and on the Behalf of Their Minor Children
14-0903
| Tex. App. | Jun 8, 2015Background
- Parents (Herrera, Garcia, Gomez) sued Clint ISD alleging intra-district funding produced large per‑student expenditure disparities among Clint, Mountain View, and Horizon schools, harming students and violating the Texas Constitution (Art. VII §1; Art. I §3).
- Complaint pleaded that the district failed to apply mandatory "weighting" factors and a "state funding formula," and relied explicitly on Tex. Educ. Code §1.002 (equal opportunities within an educational institution).
- Trial court sustained the district's plea to the jurisdiction and dismissed for failure to exhaust administrative remedies under Tex. Educ. Code §7.057; the court of appeals reversed, prompting the district's petition for review to the Texas Supreme Court.
- Central legal question: whether Plaintiffs’ claims fall within the "school laws of the state" requiring administrative exhaustion, or whether a constitutional exception (pure question of law/federal constitutional claim) permits immediate judicial review.
- Additional dispute: whether lack of injunctive power by the TEA Commissioner causes irreparable harm justifying bypass of exhaustion (and whether TEA has alternative enforcement powers, e.g., appointing a board of managers with authority to amend budgets).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject‑matter jurisdiction / exhaustion under Tex. Educ. Code §7.057 | Their suit asserts a direct constitutional violation by the district and thus is exempt from administrative exhaustion. | The pleadings principally invoke enforcement of state school laws (weighting/formula and §1.002), so Plaintiffs must exhaust district grievance/TEA remedies before suing. | Court viewed claims as arising under school laws (per pleadings) and subject to exhaustion; dismissal for lack of jurisdiction proper. |
| Scope of §1.002 and whether districts may lawfully provide unequal intra‑district funding | Plaintiffs contend the Legislature left intra‑district budgeting discretionary, so constitutional claim against district stands. | §1.002 requires equal opportunities within an educational institution; Legislature did not authorize districts to create unequal opportunities—thus statutory scheme governs. | Defendant: statute governs; intra‑district inequality is matter of school law subject to administrative review. |
| Constitutional‑exception to exhaustion (pure question of law / federal vs state constitution) | Plaintiffs argue their constitutional claims avoid exhaustion as pure constitutional issues. | The exception applies to pure questions of federal constitutional law (often in federal court) and does not apply where disputed facts must be resolved; here factual disputes about weighting exist. | Held: exception is inapplicable because Plaintiffs’ claims involve mixed questions of fact and law and are state constitutional/statutory claims. |
| Irreparable harm and TEA injunctive power | Plaintiffs assert ongoing loss of educational opportunity; TEA’s lack of injunction power produces irreparable harm necessitating court action. | Temporary injunction would have to reorder budgets (not preserve status quo) and is not available; TEA has substantial remedial powers (including appointing board of managers with authority to amend budgets), so no irremediable injury from lack of TEA injunctive power. | Held: no irreparable harm shown that would justify bypassing exhaustion; TEA enforcement tools can provide meaningful relief. |
Key Cases Cited
- West Orange‑Cove Consol. Indep. Sch. Dist. v. Alanis, 107 S.W.3d 558 (Tex. 2003) (Legislature, not districts, bears the constitutional duty to provide a suitable public school system; districts implement the Legislature's scheme)
- Neeley v. W. Orange‑Cove Consol. Indep. Sch. Dist., 176 S.W.3d 746 (Tex. 2005) (adequacy requires reasonable access and opportunity; Legislature must provide a system capable of meeting constitutional mandate)
- Van Indep. Sch. Dist. v. McCarty, 165 S.W.3d 351 (Tex. 2005) (subject‑matter jurisdiction cannot be created by waiver or estoppel)
- Texas Ass'n of Bus. v. Texas Air Control Bd., 852 S.W.2d 440 (Tex. 1993) (courts may raise lack of jurisdiction sua sponte)
- Hicks v. Lamar Consol. Indep. Sch. Dist., 943 S.W.2d 540 (Tex. App.—Eastland 1997, no writ) (constitutional‑exception to exhaustion applies only to pure legal questions)
- Dotson v. Grand Prairie Indep. Sch. Dist., 161 S.W.3d 289 (Tex. App.—Dallas 2005, no pet.) (constitutional claims ancillary to school law violations do not excuse exhaustion)
- Janik v. Lamar Consol. Indep. Sch. Dist., 961 S.W.2d 322 (Tex. App.—Houston [1st Dist.] 1997, pet. denied) (administrative exhaustion required where facts are disputed)
- Gibson v. Waco Indep. Sch. Dist., 971 S.W.2d 199 (Tex. App.—Waco 1998) (constitutional labeling does not avoid exhaustion when claim implicates school law)
- Jackson v. Houston Indep. Sch. Dist., 994 S.W.2d 396 (Tex. App.—Houston [14th Dist.] 1999, no pet.) (same principle regarding exhaustion and constitutional claims)