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The requirement to provide a basic minimum education means the state must ensure that students are afforded at least a rudimentary educational infrastructure, such that it is plausible to attain literacy within that system.
Plaintiffs in this appeal are students at several of Detroit's worst-performing public schools. They credit this substandard performance to poor conditions within their classrooms, including missing or unqualified teachers, physically dangerous facilities, and inadequate books and materials. Taken together, Plaintiffs say these conditions deprive them of a basic minimum education, meaning one that provides a chance at foundational literacy. In 2016, Plaintiffs sued several Michigan state officials, who they say are responsible for these abysmal conditions in their schools. Plaintiffs allege that state actors are responsible, as opposed to local entities, based on the state's general supervision of all public education, and also on the state's specific interventions in Detroit's public schools. The state argues that it recently returned control to local officials, and so it is now the wrong party to sue. Plaintiffs' underlying claims, brought under 42 U.S.C. § 1983, are all based on the Due Process and Equal Protection Clauses of the Fourteenth Amendment. Plaintiffs argue that while other Michigan students receive an adequate education, the students in Plaintiffs' schools do not, amounting to a violation of their right to equal protection of the laws. They also argue that the schools they are forced to attend are schools in name only, and so the state cannot justify the restriction on their liberty imposed by compulsory attendance. And in their most significant claim, Plaintiffs ask this Court to recognize a fundamental right to a basic minimum education, an issue the Supreme Court has repeatedly discussed but never decided.
While the district court found that Defendants were in fact the proper parties to sue, it dismissed Plaintiffs' complaint on the merits. First, it found that Plaintiffs had not alleged a proper comparator for their equal protection claim, nor had they highlighted any state policy or action that was not supported by a rational basis. Second, it found that Plaintiffs had not sufficiently pleaded their compulsory attendance theory, and so the court only viewed their due process claim as seeking an affirmative fundamental right. Third, the court held that a basic minimum education is not a fundamental right, and so Plaintiffs' due process claim was dismissed. Plaintiffs then appealed.
Were the plaintiffs able to properly plead that they have been denied a basic minimum education, and thus have been deprived of access to literacy?
The Court held that it was evident from the Michigan Constitution and statutes, as well as its prior interventions in the school system, that the State retained significant authority over the city's public schools, and thus, its officers were proper defendants in the case under Ex parte Young, and the transfer of some control back to local officials did not render the lawsuit moot. The Constitution provided a fundamental right to a basic minimum education, and taking as true plaintiff students' allegations concerning inadequate books and materials, insufficient or unqualified teaching staff, and decrepit and dangerous school conditions, and that nearly zero percent of students at their schools were graded as proficient in English or other subject-matter tests administered by the state, the students plausibly alleged that defendants denied them a basic minimum education.