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Law School Case Brief

Comm. for Educ. Rights v. Edgar - 174 Ill. 2d 1, 220 Ill. Dec. 166, 672 N.E.2d 1178 (1996)

Rule:

The meaning of a constitutional provision depends on the common understanding of the citizens who, by ratifying the constitution, gave it life. This understanding is best determined by referring to the common meaning of the words used. Where the language is unambiguous, it will be given effect without resort to other aids for construction. However, if after consulting the language of a provision, doubt remains as to its meaning, it is appropriate to consult the debates of the delegates to the constitutional convention to ascertain the meaning they attached to the provision.

Facts:

Plaintiffs the Committee for Educational Rights, dozens of boards of education, and several students and their parents, filed a lawsuit in Illinois state court against defendants Jim Edgar, the Governor of Illinois, the State Board of Education, and Joseph A. Spagnolo, the State Superintendent of Education, seeking a declaratory judgment that the statutory scheme governing the funding of public schools violated various provisions of the Illinois Constitution of 1970. Specifically, plaintiffs claimed that the current financing scheme and the general state aid formula did not effectively equalize funding among wealthy and poor districts. On defendants' motion, the trial court dismissed plaintiffs' complaint for failure to state a cause of action. The appellate court affirmed. Plaintiffs appealed, contending that the trial court erred in dismissing their claims under the equal protection clause, Ill. Const. art. I, § 2, and the education article, Ill. Const. art. X, §1.

Issue:

Did the statutory scheme that governed the funding of public schools violate the Illinois Constitution?

Answer:

No.

Conclusion:

The state supreme court affirmed the appellate court's judgment. The court held that disparities in educational funding that resulted from differences in local property wealth did not offend the efficiency requirement found in Ill. Const. art. X, § 1. The court also held that the question of whether the educational institutions and services were high quality was outside the sphere of the judicial function. The court determined that the process of reform had to have been undertaken in a legislative forum rather than in the judicial system.

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