Lobato v. State, 2013 CO 30

Plaintiffs filed in 2005 for declaratory and injunctive relief alleging Colorado’s public school financing violates the Education Clause and the Local Control Clause.
The trial court dismissed the complaint on standing and political-question grounds; the court of appeals affirmed.
The Colorado Supreme Court granted certiorari, reversed the court of appeals on standing and justiciability, and remanded for proof of allegations.
Evidence at trial led to a ruling that the system is not rationally related to the Education Clause, and the trial court enjoined the current funding system.
The issues on appeal were: (i) justiciability of the claims under political-question and law-of-the-case principles; (ii) whether the funding system is rationally related to the Education Clause under Lobato I; (iii) whether the system complies with the Local Control Clause.
The Court ultimately held the funding system is rationally related to the Education Clause, and constitutional under the Local Control Clause, reversing the trial court’s injunction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the claims are justiciable as a matter of law	Lobato I held justiciable questions	Questions framed as policy concerns are non-justiciable	Justiciable (not a political question)
Whether the PSFA is rationally related to the Education Clause's thorough and uniform mandate	System underfunding and disparities fail to be rational	System is rationally related and uniform in application	Rationally related to the mandate
Whether the dual-funded system complies with the Local Control Clause	Local control is eroded by state finance structure	System preserves local control over locally raised funds	Complies with Local Control Clause
Whether the Court should overturn prior law-of-the-case determinations	Changed conditions justify reconsideration	Law-of-the-case should be followed	Law-of-the-case maintained; prior rulings preserved
Whether the Court should fashion a remedy or require reform by the legislature	System must be restructured to meet constitutional standards	Policy choices are for the legislature; court should not dictate specifics	Court refrains from prescribing policy details; enables legislative reform

Lobato v. State, 218 P.3d 358 (Colo. 2009) (set the Lobato I rational-basis framework for education financing)
Lujan v. Colorado State Board of Education, 649 P.2d 1005 (Colo. 1982) (established the rational relation concept for Education Clause scrutiny)
Owens v. Colo. Cong. of Parents, Teachers & Students, 92 P.3d 933 (Colo. 2004) (affirmed judicial deference to legislative policy in education funding)
DeRolph v. State, 78 Ohio St.3d 193, 677 N.E.2d 733 (Ohio 1997) (interpreting thorough and efficient/adequate standards in funding cases (cited in context))
Mesa County Bd. of Cnty. Comm'rs v. State, 203 P.3d 519 (Colo. 2009) (upheld dual-funded system respecting local control)