Haridopolos v. Citizens for Strong Schools, Inc.
2011 Fla. App. LEXIS 18738
| Fla. Dist. Ct. App. | 2011Background
- Petitioners seek writ of prohibition to halt circuit court proceedings challenging Florida’s K-12 education funding and policy as unconstitutional under Art. IX, §1(a).
- Trial court denied motion to dismiss respondents’ amended complaint for declaratory and supplemental relief.
- Court must decide whether Art. IX, §1(a) provides judicially enforceable standards for a statewide adequacy/quality review.
- Amended complaint alleges systemic funding and policy failures, including spending levels, distribution, teacher resources, safety, and accountability.
- The Florida Supreme Court previously limited judicial review of adequacy in Coalition, prompting amendment in 1998 to add terms like“efficient,”“safe,”“secure,” and“high quality.”
- The plurality denies prohibition but certifies a question to the Supreme Court about judicially ascertainable standards for evaluating statewide education adequacy
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Article IX, §1(a) provide judicial standards to assess statewide education adequacy? | Respondents rely on amended §1(a) with added descriptors as manageable standards. | Petitioners contend standards are non-justiciable political questions lacking judicially manageable criteria. | No definitive standards; certification allowed to resolve standards issue. |
| Is the circuit court's jurisdiction proper to adjudicate respondents’ declaratory relief claims under the amendment? | Respondents seek declaratory relief and remedial measures implementing the constitutional values. | Petitioners argue such relief would encroach on legislative appropriations and policy setting. | Prohibition denied; circuit court jurisdiction is not clearly beyond scope at this stage. |
| Is the provision self-executing or requiring implementing legislation? | Respondents urge judicial enforcement of an enforceable constitutional duty. | Petitioners argue the amendment requires legislative action by law, not self-execution. | Not self-executing; implementation requires law; standards remain non-justiciable without enactment. |
| Should the court permit implementing-relief directing policy/appropriations? | Respondents request remedial plan and studies to determine resources/standards. | Courts may not set appropriations or compel policy changes; separation of powers. | Writ denied on prohibitory grounds; potential implementing relief questions reserved for later. |
| Does the 1998 amendment cure Coalition’s deficiency allowing judicial review? | Amendment provides objective standards for judging adequacy. | Standards are still vague; judicial review remains improper for policy/economic judgments. | Amendment does not render education adequacy justiciable; standard remains non-justiciable without clear metrics. |
Key Cases Cited
- Coalition for Adequacy & Fairness in School Funding, Inc. v. Chiles, 680 So.2d 400 (Fla. 1996) (held adequacy non-justiciable without definable standards; legislature has discretion)
- Bush v. Holmes, 919 So.2d 392 (Fla. 2006) (amendment to §1 strives to provide standards; but enforceability depends on text itself)
- King, School Bd. of Miami-Dade County v. King, 940 So.2d 593 (Fla. 1st DCA 2006) (dissent cites judicial review of constitutional education provisions; relevance to implementing standards)