William Penn SD, Aplts v. Dept of Educ
46 MAP 2015
| Pa. | Sep 28, 2017Background
- Plaintiffs (school districts, parents, PARSS, PA NAACP) filed a petition seeking declaratory and injunctive relief challenging Pennsylvania’s school-funding system under the Education Clause (PA Const. art. III, §14) and the state Equal Protection provision (art. III, §32).
- Plaintiffs alleged funding shortfalls relative to state academic standards (PSSA, Keystone, Common Core) and relied on a 2008 costing‑out study estimating substantial per‑pupil funding gaps; they sought orders requiring a funding scheme reasonably calculated to enable all students to meet state standards.
- Defendants (Governor, Department/Board of Education, legislative leaders) demurred, asserting the claims present non‑justiciable political questions, lack judicially manageable standards, and implicate separation of powers and sovereign immunity.
- The Commonwealth Court sustained demurrers, dismissing the Petition as non‑justiciable under Pennsylvania precedent; Plaintiffs appealed to the Supreme Court of Pennsylvania.
- Chief Justice Saylor (dissent) argued the disputes remain non‑justiciable under settled Pennsylvania law (Danson, Marrero II), and alternatively held the Equal Protection claim fails on the merits (no fundamental right established; rational‑basis review applies and the petition’s allegations are insufficient).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Justiciability of Education Clause claim | Courts can adjudicate now because state academic standards and costing‑out study supply judicially manageable benchmarks | Education funding/design are policy questions textually committed to political branches; no manageable judicial standards; Marrero/Danson control | Non‑justiciability (dissent would hold claims political questions); courts traditionally defer to Legislature on adequacy and funding policy |
| Use of academic standards / costing‑out as judicial benchmarks | PSSA/Keystone/Common Core and costing‑out study provide objective measures of adequacy and cost | Standards are political/administrative judgments subject to change; relying on them would bind future legislatures and create judicial micromanagement | Court should not convert legislative/administrative standards into constitutional minima; using them as binding judicial benchmarks is problematic |
| Equal Protection — is education a fundamental right triggering strict scrutiny? | Education is a fundamental right; funding disparities should trigger strict scrutiny | Education is not a fundamental constitutional right under the state constitution; Marrero II forecloses treating it as such | No fundamental right under state constitution for this purpose; strict scrutiny not triggered (dissent would disapprove contrary dicta in Wilkinsburg) |
| Equal Protection — rational‑basis challenge to funding disparities | Funding scheme is irrational and arbitrarily disadvantages low‑wealth districts; reliance on local property tax produces gross disparities | Funding system reasonably relates to legitimate interests (local control, reliance on local revenue, targeted state aid); claims are enmeshed with Education Clause political questions | Petition’s allegations insufficient to state an Article III, §32 violation; given local/state scheme and state aid formulas, plaintiffs failed to show lack of any rational basis; equal‑protection claim dismissed |
Key Cases Cited
- Marrero v. Commonwealth, 559 Pa. 14 (1999) (approving Commonwealth Court’s abstention reasoning and holding Education Clause challenges raise non‑justiciable political questions in context presented)
- Danson v. Casey, 484 Pa. 415 (1979) (held court may not define or enforce a judicially manageable standard of a "thorough and efficient" education; funding scheme bore reasonable relation to Education Clause)
- Teachers’ Tenure Act Cases, 329 Pa. 213 (1938) (discussed Legislature’s broad authority under Education Clause and the limits on judicial second‑guessing of education policy)
- Wilson v. School Dist. of Philadelphia, 328 Pa. 225 (1937) (early expression of judicial deference to legislative and school board discretion in education matters)
- Baker v. Carr, 369 U.S. 186 (1962) (political question factors framework used to assess justiciability)
- San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973) (federal precedent that education is not a fundamental right under the U.S. Constitution; discusses local control and funding disparities)
- Reichley v. N. Penn Sch. Dist., 533 Pa. 519 (1993) (applied reasonable‑relation test to education‑related statute and emphasized judicial restraint)