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Fla. Const. art. II, § 3 expressly sets forth the separation of powers doctrine: The powers of the state government shall be divided into legislative, executive and judicial branches. No person belonging to one branch shall exercise any powers appertaining to either of the other branches unless expressly provided herein.
In a one-count complaint, petitioner Coalition for Adequacy & Fairness in School Funding sought declaratory relief against Chiles et al. and asked the trial court to declare that an adequate education is a fundamental right under the Florida Constitution, and that the State has failed to provide its students that fundamental right by failing to allocate adequate resources for a uniform system of free public schools as provided for in the Florida Constitution. In support of their action, the Coalition alleged: (1) Certain students are not receiving adequate programs to permit them to gain proficiency in the English language; (2) Economically deprived students are not receiving adequate education for their greater educational needs; (3) Gifted, disabled, and mentally handicapped children are not receiving adequate special programs; (4) Students in property-poor counties are not receiving an adequate education; (5) Education capital outlay needs are not adequately provided for; and (6) School districts are unable to perform their constitutional duties because of the legislative imposition of noneducational and quasi-educational burdens. The trial court dismissed the complaint with prejudice.
Did the trial court err in dismissing the complaint of the Coalition?
There was an insufficient showing has been made to justify judicial intrusion. As the Article II, section 3 of the Florida Constitution demonstrates, each branch of government has certain delineated powers that the other branches of government may not intrude upon. For instance, the power to appropriate state funds is expressly reserved to the legislative branch. More specifically, article VII, section 1(c) provides: "No money shall be drawn from the treasury except in pursuance of appropriation made by law." Thus, it is well settled that the power to appropriate state funds is assigned to the legislature.
The United States Supreme Court in Baker v. Carr set forth six criteria to gauge whether a case involves a political question: (1) a textually demonstrable commitment of the issue to a coordinate political department; (2) a lack of judicially discoverable and manageable standards for resolving it; (3) the impossibility of deciding without an initial policy determination of a kind clearly for nonjudicial discretion; (4) the impossibility of a court's undertaking independent resolution without expressing lack of the respect due coordinate branches of government; (5) an unusual need for unquestioning adherence to a political decision already made; and lastly (6) the potentiality of embarrassment from multifarious pronouncements by various departments on one question. Chiles et al. claim that at least the first two of these criteria mandate affirmance here. Chiles et al. suggest that the constitution has committed the determination of "adequacy" to the legislature, and that there is a "lack of judicially discoverable and manageable standards" to apply to the question of "adequacy." That is, Chiles et al. assert that there are no judicially manageable standards available to determine adequacy. In contrast, they note that the phrase "uniform" has manageable standards because by definition this word means a lack of substantial variation. By contrast, Chiles et al. contend, "adequacy" simply does not have such straightforward content. The Court agrees with Chiles et al. While it stops short of saying "never," the Coalition et al. have failed to demonstrate in their allegations, or in their arguments on appeal, an appropriate standard for determining "adequacy" that would not present a substantial risk of judicial intrusion into the powers and responsibilities assigned to the legislature, both generally (in determining appropriations) and specifically (in providing by law for an adequate and uniform system of education).