SCHOOL DISTRICTS'ALLIANCE v. State
244 P.3d 1
Wash.2010Background
- Alliance of school districts challenges Washington's special education funding under Article IX, section 1 of the state constitution.
- Washington funds special education through BEA, excess cost funding, and a safety net, with BEA allocations based on district-wide average enrollment.
- Special education students are entitled to the full BEA, and the BEA is intertwined with basic education funding.
- Trial court ruled Alliance failed to prove unconstitutionality beyond a reasonable doubt; Court of Appeals affirmed.
- The Supreme Court granted review to decide the proper standard of review, BEA inclusion in funding calculations, and whether Article VIII, section 4 precludes applying BEA to special education.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What is the proper standard for constitutional challenge to the funding mechanism? | Alliance argues for a lower standard. | State argues for beyond a reasonable doubt. | Beyond a reasonable doubt standard applies. |
| Should BEA be included when determining adequacy of funding for special education? | Alliance seeks to decouple BEA from special education funding. | State contends BEA must be included. | BEA must be included; funding mechanism not unconstitutional beyond a reasonable doubt. |
| Does Article VIII, §4 preclude applying BEA to fund special education? | Alliance argues BEA cannot fund special education. | Chapter 518 allocations allow BEA and excess costs to fund education, including special education. | Article VIII, §4 is not violated; BEA can be applied to fund special education. |
Key Cases Cited
- Seattle Sch. Dist. No. 1 v. State, 90 Wn.2d 476 (1978) (paramount duty to provide education; legislature deference in funding)
- Island County v. State, 135 Wn.2d 141 (1998) (beyond a reasonable doubt standard for constitutional challenges)
- Tunstall v. Bergeson, 141 Wn.2d 201 (2000) (demonstrates deference to legislature; high standard for constitutional challenges)
- Brown v. State, 155 Wn.2d 254 (2005) (applies beyond a reasonable doubt to funding/education questions)
- Parrott & Co. v. Benson, 114 Wash. 117 (1921) (early articulation of the beyond-a-reasonable-doubt standard)