School Districts' Alliance for Adequate Funding of Special Education v. State, 244 P.3d 1

Washington Constitution requires the State to make ample provision for education of all children, with the paramount duty to provide basic education via dependable tax sources.
Special education in Washington is funded through three mechanisms: BEA (base funding based on district enrollment), excess cost funding (0.9309 multiplier of BEA for special education), and the state safety net for demonstrated unmet needs.
The BEA is said to be fully funding basic education and also used as part of funding for special education as a class, not merely gross basic education funds.
The Alliance contends the BEA should be excluded from calculations determining adequacy of funding for special education, and that the funding mechanism underfunds special education beyond a reasonable doubt.
The trial court held the Alliance must show underfunding beyond a reasonable doubt and include BEA in calculations; the Court of Appeals affirmed.
The Washington Supreme Court granted review to determine the proper standard, whether BEA must be included, and whether Article VIII, §4 precludes BEA application to special education.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What standard governs constitutional challenges to funding?	Alliance argues the standard should be lower for appropriations.	State argues the traditional beyond a reasonable doubt standard applies.	Beyond a reasonable doubt standard applies.
Whether BEA must be included in calculating special education funding?	Alliance argues BEA should be excluded from the calculation.	State//majority believes BEA must be included as BEA funds basic education and is intertwined with special education.	BEA must be included in funding calculations.
Does Article VIII, §4 preclude applying BEA to fund special education?	Alliance contends BEA funds cannot be used for special education.	Legislative scheme allocates BEA and excess costs; BEA can be used consistent with law.	Article VIII, §4 is not violated; BEA can be applied to fund special education within the statutory scheme.

Seattle Sch. Dist. No. 1 v. State, 90 Wn.2d 476 (1978) (established paramount duty to provide basic education and deference to legislature in means chosen)
Parrott & Co. v. Benson, 114 Wash. 117 (1921) (statutes presumed constitutional; high standard to overcome)
Island County v. State, 135 Wn.2d 141 (1998) (beyond a reasonable doubt standard for constitutional challenges; deference to legislature)
Tunstall v. Bergeson, 141 Wn.2d 201 (2000) (recognizes deference to legislative judgment in funding matters)
Brown v. State, 155 Wn.2d 254 (2005) (used beyond a reasonable doubt standard in article IX challenges)
Wash. Fed’n of State Emps. v. State, 127 Wn.2d 544 (1995) (presumption of constitutionality; heavy burden on challenger)
City of Seattle v. Ludvigsen, 162 Wn.2d 660 (2007) (de novo review for some constitutional questions; not extensive cited here but relevant to standard debates)