Madison Metropolitan School District v. Circuit Court, 800 N.W.2d 442

MT, a 15-year-old, was expelled from Madison East High School after being found with marijuana; the expulsion order barred educational services for at least one semester.
A separate Dane County delinquency petition was filed against MT, with dispositions involving educational planning.
Dane County court ordered the District to provide MT with minimally adequate educational resources, prompting the District to offer its own plan and to seek appellate review.
The circuit court issued an order to provide educational resources to MT despite the expulsion, basing authority on statutes including 938.45 and 938.34(7d).
The Court of Appeals granted a supervisory writ prohibiting the circuit court’s order; the Supreme Court granted review to resolve circuit court authority in this context.
The Supreme Court affirmed the Court of Appeals, concluding no statutory authority authorizes ordering a district to provide alternative educational resources to an expelled student, and that a supervisory writ was appropriately used in this context.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the circuit court have authority to order educational services for an expelled student?	District argues expulsion terminates education obligations and §938.34(7d) does not authorize district-created programs post-expulsion.	Flanagan contends the Juvenile Justice Code enables broad circuit court dispositional authority to secure educational services.	No; circuit court lacks authority to order such services.
Was the court of appeals' use of a supervisory writ proper?	District contends writ is inappropriate because an appeal would be adequate.	Court of Appeals appropriately used supervisory writ to prevent circuit court overreach.	Yes; writ of prohibition proper.
How do §938.45 and related statutes interact with a district’s expulsion authority?	District cannot be subjected to authority over an expulsion decision or duties to provide education.	Circuit court relied on these provisions to require educational planning.	Statutory text does not authorize district to provide direct education post-expulsion; district is not a “person” for §938.45.

Dressier v. Circuit Court for Racine County, 163 Wis. 2d 622 (Wis. Ct. App. 1991) (five-factor test for supervisory writs; writs are extraordinary remedies)
State ex rel. DPI v. DILHR, 68 Wis. 2d 677 (Wis. 1975) (writs and authority limits; use of extraordinary remedies)
Kalal v. Kalal, 271 Wis. 2d 633 (Wis. 2004) (statutory interpretation framework (plain meaning, context))
Burnett v. Alt, 224 Wis. 2d 72 (Wis. 1999) (five-factor Dressier-based standard for prohibition relief)
State v. Hezzie R., 219 Wis. 2d 848 (Wis. 1998) (context on juvenile dispositional authority)
State ex rel. Lynch v. County Court, Branch III, 82 Wis. 2d 454 (Wis. 1978) (harm inherent in the situation standard for extraordinary relief)