Citizens for Strong Sch., Inc. v. Fla. State Bd. of Educ. - 262 So. 3d 127 (Fla. 2019)

Rule:

The legislature has been vested with enormous discretion by the Florida Constitution to determine what provision to make for an adequate and uniform system of free public schools.

Facts:

This case began in November 2009—in the wake of the Great Recession—when certain public school students, parents, and citizen organizations (collectively, Petitioners) filed suit against the State Board of Education, the President of the Florida Senate, the Speaker of the Florida House of Representatives, and the Florida Commissioner of Education (collectively, Respondents) seeking a declaration that the State is breaching its paramount duty under article IX, section 1(a). Or as the First District later described it, Petitioners' claim is "that the State's entire K-12 public education system—which includes 67 school districts, approximately 2.7 million students, 170,000 teachers, 150,000 staff members, and 4,000 schools—is in violation of the Florida Constitution."  In their complaint, Petitioners cited the 1998 amendments to article IX, section 1 and asserted that "adequate provision" and "high quality" are to be "measured by both the enumerated characteristics of and inputs into the system itself as well as the outcome results of that system." Petitioners largely focused on purported inadequacies in funding and alleged that the "2009 Appropriations Act for K-12 education violates the Education Clause of the Florida Constitution." Petitioners also criticized, among other things, the State's "current accountability policy," "misus[e]" of standardized test results, inadequate graduation rates, and achievement test results. Petitioners further alleged that the State's alleged "failure to provide a high quality education disproportionately impacts minority, low income and students with disabilities." In the end, Petitioners requested that the trial court order Respondents "to establish a remedial plan that conforms with the Florida Constitution." Petitioners later amended their complaint to request that the remedial plan "include[] necessary studies to determine what resources and standards are necessary to provide a high quality education to Florida students." The trial court held that the arguments "raise political questions not subject to judicial review, because the relevant constitutional text does not contain judicially discoverable standards by which a court can decide whether the State has complied with organic law." The trial court also found that Florida's "strict separation of powers . . . requires judicial deference to the legislative and executive branches to adopt and execute educational policies those branches deem necessary and appropriate to enable students to obtain a 'high quality' education." The appellate court affirmed.

Issue:

Did the appellate court err in affirming the trial court's decision rejecting the challenge based on the Coalition case, notwithstanding the 1998 amendments to § 1(a)?

Answer:

No.

Conclusion:

The court held that the appellate court did not err by affirming the trial court's decision rejecting the challenge based on the Coalition case, notwithstanding the 1998 amendments to § 1(a), because petitioners failed to present any manageable standard by which to avoid judicial intrusion into the powers of the other branches of government. The court held that the term "high quality" as used in § 1(a) did not have straightforward content, and that petitioners wanted the court to intrude into the legislature's appropriations power and inject itself into education policy making and oversight, which the court refused to do.