Intermediate courts of appeal in California and Florida (but not the state supreme courts) have recently held that adequacy language in the state’s education clause does not have a “qualitative” dimension that courts can properly interpret in order to assess whether students are receiving an adequate education. Late last month, the Minnesota Supreme Court decided otherwise (Cruz-Guzman v State). In a major decision that has important implications for cases challenging funding inequities, racial segregation and inadequate civic education, the Minnesota Supreme Court held that:
The framers [of the state constitution] could not have intended for the Legislature to create a system of schools that was “general and uniform” and “thorough and efficient” but that produced a wholly inadequate education, … [As long ago as 1871], we recognized that the people of Minnesota have a right to “an education which will fit them to discharge intelligently their duties as citizens of the republic.” … An education that does not equip Minnesotans to discharge their duties as citizens intelligently cannot fulfill the Legislature’s duty to provide an adequate education under the Education Clause.¹
The Court also discussed at length why claims of violations of the Education Clause of the state constitution are justiciable, noting that “Deciding that appellants’ claims are not justiciable would effectively hold that the judiciary cannot rule on the Legislature’s noncompliance with a constitutional mandate, which would leave Education Clause claims without a remedy. Such a result is incompatible with the principle that where there is a right, there is a remedy.”
Plaintiffs in Cruz-Guzman claimed that school children in public schools throughout the state of Minnesota, including the city of Minneapolis, the City of Saint Paul, and their adjacent suburban communities, are largely segregated by race and socioeconomic status, and that a “segregated education is per se an inadequate education under the Education Clause of the Minnesota State Constitution.” The case will now go to trial where the parties will present evidence on that question.
Two of the members of the Court dissented, arguing among other things, that the issues are not justiciable and that prior adequacy cases in Minnesota and elsewhere interpreted constitutional educational provisions to apply only to finance issues and not to “adequacy” as broadly defined by the present plaintiffs.
To date, Connecticut’s Supreme Court is the only state high court that has held that patterns of school segregation violate the educational clause of the state constitution. See, Sheff v.O’Neill, 678 A.2d 1267 (1996). That ruling was based both on the education clause in the state constitution and a provision that specifically banned segregation. If it finds in plaintiffs’ favor, the Minnesota court would be the first in the country to uphold a desegregation claim based solely on a right to education provision in a state constitution.
¹ Art XIII, § 1.of the Minnesota Constitution, adopted in 1857, provides: “The stability of a republican form of government depending mainly upon the intelligence of the people, it is the duty of the legislature to establish a general and uniform system of public schools. The legislature shall make such provisions by taxation or otherwise as will secure a thorough and efficient system of public schools throughout the state.”