¶ 1. Plaintiffs, a group of public-school students and a group of taxpayers, appeal a superior court decision dismissing their complaint pursuant to Vermont Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted. Plaintiff students contend that Act 60 fails to protect their right to an equal educational opportunity under the Vermont Constitution. Plaintiff taxpayers assert that Act 60’s method of taxation to fund education violates their rights under the Vermont Constitution because it imposes a disproportionate burden upon the taxpayers in their towns compared to similarly situated taxpayers in other towns. The superior court dismissed both claims on grounds of judicial self-restraint. We reverse the superior court’s decision, and remand for further proceedings.
¶ 2. Plaintiff students are four children who attend Whitingham School, Wilmington Middle High School, and Chester-Andover Elementary School. They argue that the State has failed to provide them with a substantially equal educational opportunity in violation of Chapter I, Article 7
¶ 3. Plaintiff taxpayers are ten property owners who reside in Whitingham, Wilmington, and Andover, and pay local and state education taxes to their respee
¶ 4. The State moved to dismiss the complaint under Rule 12(b)(6) for failure to state a claim upon which relief can be granted, Rule 12(b)(1) for lack of subject-matter jurisdiction, and Rule 12(b)(7) for failure to join indispensable parties.
¶ 5. After the State filed its motion to dismiss, plaintiffs moved to amend their complaint pursuant to Rule 15(a). They sought amendment to update the statutory sections in their complaint that referred to Act 60, so that their complaint would also refer to the pertinent statutory sections of Act 68. Plaintiffs did not seek to alter their legal argument on the constitutionality of the education-funding system; they explained that Act 68 did not remedy the defects of Act 60 identified in their original complaint. Rather, they moved to amend the references to Act 60 contained in their complaint.
¶ 6. The superior court ruled concurrently on the State’s motion to dismiss and the plaintiffs’ motion to amend. The court granted the motion to dismiss and thus denied plaintiffs’ motion to amend as moot. Without basing its decision on one identifiable legal theory, the court relied on a general notion of judicial restraint to reach the conclusion that the court should not hear the case. The court interpreted our decision in Brigham I as requiring the courts to let the Legislature remedy Vermont's education-funding system’s deficiencies without judicial interference. Explaining that the issue is not nonjusticiable per se, the court stated:
As Brigham exemplifies, the constitutionality of school funding is not non-justiciable in an absolute sense. But the modes of judicial self-restraint have more prudential texture than that of the classic political question doctrine alone. Mootness and ripeness issues aside, the continuation of this ease would not only be disrespectful*527 of the political process underway, it could harm the political process by delaying it or distracting attention and resources more productively focused on it, or derailing it with unnecessary mandates or, worse, the unnecessary perception of mandates. The Legislature has not responded to Brigham by refusing to act, or by acting halfheartedly; the Legislature plainly heard Brigham’s beacon and is now finding its way. Rather than enforcing Brigham, this litigation runs counter to it. (citation omitted).
¶ 7. Plaintiffs contend on appeal that the superior court erred in granting the State’s motion to dismiss. They argue that it is the role of the judiciary to determine whether the state-education-funding system violates their constitutional rights.
¶ 8. The issue in this case is whether the superior court erred in granting the State’s motion to dismiss on grounds of judicial restraint. Our decision in Brigham I recognizes that the court has a duty to hear plaintiffs’ claims on the alleged constitutional deficiencies of the education-funding system. Therefore, because plaintiffs have pleaded facts sufficient to satisfy the liberal Rule 12(b)(6) standard, the plaintiffs’ claims must be allowed to go forward. We emphasize that although plaintiffs may not ultimately prove the alleged violations once a full record is developed, a Rule 12(b)(6) motion is not the proper procedure for testing the factual support for plaintiffs’ claims. We reverse and remand for further proceedings, including a ruling on plaintiffs’ motion to amend their complaint.
¶ 9. Rather than conducting an analysis on whether plaintiffs met the requirements of Rule 12(b)(6), the superior court improperly relied on the notion of judicial restraint in dismissing the complaint. The doctrine of judicial self-restraint derives from Article III of the United States Constitution, which states that federal courts have jurisdiction only over actual cases or controversies. U.S. Const. art. III, § 2, cl. 1; Parker v. Town of Milton,
¶ 10. Adjudicating cases involving alleged violations of plaintiffs’ constitutional rights resulting from a legislative enactment does not undermine the legislative process, nor is it disrespectful of the other branches of government.
¶ 11. The purpose of a Rule 12(b)(6) motion is “to test the law of the claim, not the facts which support it.” Powers v. Office of Child Support,
¶ 12. The State advances several arguments, many of which go to the merits of plaintiffs’ case, in favor of dismissing the complaint. At this early stage in the litigation, however, a court should be reluctant to dismiss a plaintiff’s claims, and should not consider the merits of whether a plaintiff’s claims will ultimately succeed. See Sprague,
¶ 13. The State first argues that plaintiffs have not met their burden under Rule 12(b)(6) because their allegations fail to demonstrate that they receive an unequal educational opportunity compared to students attending other Vermont school districts. To support their claim that the State has violated their constitutional right to an equal educational opportunity under Brigham I, the students alleged that the State does not provide adequate funding for education. The students argued that because of Act 60’s inadequate funding, their schools do not have enough money to spend on curriculum. They alleged that Whitingham
¶ 14. The State next argues that the taxpayers’ claim should be dismissed under Rule 12(b)(6) because they failed to raise any constitutional defects in Act 60. The State argues that the taxpayers will not be able show that Act 60’s taxation system lacks a rational basis, and then concludes on the merits of plaintiffs’ case that “[t]his tax scheme is rationally related to the objective of providing substantially equal access to education revenues.”
¶ 15. The taxpayers allege that Act 60 violates their constitutional right to be taxed the same as other similarly situated taxpayers. In One Church Street, we set out the basic requirements of the Proportional Contribution Clause. In re Property of One Church St. City of Burlington,
¶ 16. The State also argues that we should dismiss the complaint because plaintiffs lack standing to maintain their claims. To satisfy the standing requirement, a plaintiff must show: (1) injury-infaet, (2) causation, and (3) redressability. Parker,
¶ 17. The State’s arguments that plaintiffs do not have standing ignore our decision in Brigham I. Just as the students and taxpayers in Brigham I had standing to maintain their claims for unequal educational opportunity and disproportionate taxation, the plaintiffs in this ease, who allege the same type of injuries, also have standing. Plaintiffs here seek an injunction and declaration that Act 60 is unconstitutional. Just as the plaintiffs’ injuries in Brigham 1 were remedied by our declaration that the Foundation Plan was unconstitutional,
¶ 18. The State’s final argument is that the court lacks subject-matter jurisdiction because plaintiffs’ claims were mooted by Act 68 and the consolidation of the Whitingham and Wilmington school districts. The State contends that Act 68 corrected the alleged constitutional deficiencies of Act 60’s funding mechanisms, and that the consolidation of the schools
Reversed and remanded.
Notes
Chapter I, Article 7, in part, provides: “That government is, or ought to be, instituted for the common benefit, protection, and security of the people, nation, or community, and not for the particular emolument or advantage of any single person, family, or set of persons, who are a part only of that community ----” Vt. Const. ch. I, art. 7.
Chapter II, § 68, in part, provides: “Laws for the encouragement of virtue and prevention of vice and immorality ought to be constantly kept in force, and duly executed; and a competent number of schools ought to be maintained in each town unless the general assembly permits other provisions for the convenient instruction of youth....” Vt. Const. ch. II, § 68.
Chapter I, Article 9, in part, provides: “That every member of society hath a right to be protected in the enjoyment of life, liberty, and property, and therefore is bound to contribute the member’s proportion towards the expense of that protection____” Vt. Const. ch. I, art. 9.
The State did not raise on appeal the issue of whether the plaintiffs’ failure to join the school districts as indispensable parties warrants dismissal under Rule 19. Thus, we decline to consider this argument here.
In its decision, the superior court referred to an ongoing effort in the Legislature to address the education-funding system. There is nothing in the record to indicate that such a process is occurring; therefore, we decline to consider its relevance here.