Independent School District No. 5 of Tulsa County v. Spry, 292 P.3d 19

Oklahoma school districts challenged an Act as unconstitutional under the Oklahoma Constitution.
The districts sought to challenge the apparent withholding of state funds to parents for private school payments.
The Supreme Court denied oral argument and all amicus curiae briefs for lack of standing/justiciable issues.
The Court defines standing as a direct, immediate, and substantial interest with concrete injury in fact and causal connection.
The funds at issue are a general grant from the Legislature via the State Department of Education, not tax revenues to be misused by a local county.
The districts are not taxpayers and thus not proper parties to challenge the expenditure of public funds; parents are likewise not proper parties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do the school districts have standing to challenge the Act?	Districts contend they possess a direct, substantial interest to challenge funding and compliance.	Districts lack injury in fact and are not taxpayers; funds are the Legislature's vehicle, not district revenue.	No; standing not established; case dismissed.
Are parents or taxpayers proper parties to challenge the expenditure of public funds?	Taxpayers/parents have standing to challenge improper public fund use.	Parents are not proper parties for these constitutional challenges; districts bear the challenge as non-taxpayer entities.	Parents are not proper parties; standing requirements unmet.

Fent v. Contingency Review Board, 2007 OK 27 (OK 27, 18, 163 P.3d 512) (taxpayer challenge to public funds as a public-right matter)
Oklahoma Educ. Ass'n v. State ex rel. Oklahoma Legislature, 2007 OK 30 (OK 30, 158 P.3d 1058) (standing inquiry; injury to a legally protected interest)
Indep. School Dist. No. 9 of Tulsa County v. Glass, 1982 OK 2 (OK 2, 689 P.2d 1233) (proper inquiry for standing; plaintiff must show injury)
Estate of Doan v. First Nat'l Bank and Trust Co. of Tulsa, 1986 OK 15 (OK 15, 727 P.2d 574) (standing related to public funds challenges)
Underside v. Lathrop, 1982 OK 57 (OK 57, 645 P.2d 514) (standing principles for government suits)
Flast v. Cohen, 392 U.S. 83 (1968) (constitutional standing requirements; injury in fact)
Wells Fargo Bank, N.A. v. Heath, 2012 OK 54 (OK 54, 280 P.3d 328) (reiterates standing and injury-in-fact principles)
Indep. Sch. Dist. No. 9 of Tulsa County v. Glass (repeat citation), 1982 OK 2 (OK 2, 689 P.2d 1233) (see above; standing analysis framework)