Law School Case Brief
Horne v. Flores - 557 U.S. 433, 129 S. Ct. 2579 (2009)
Fed. R. Civ. P. 60(b)(5) permits a party to obtain relief from a judgment or order if, among other things, applying the judgment or order prospectively is no longer equitable. Rule 60(b)(5) may not be used to challenge the legal conclusions on which a prior judgment or order rests, but the rule provides a means by which a party can ask a court to modify or vacate a judgment or order if a significant change either in factual conditions or in law renders continued enforcement detrimental to the public interest. The party seeking relief bears the burden of establishing that changed circumstances warrant relief, but once a party carries this burden, a court abuses its discretion when it refuses to modify an injunction or consent decree in light of such changes.
Plaintiffs, a group of English language-learner (ELL) students and their parents, filed a class action, alleging that defendants, Arizona, its state board of education, and the superintendent of public instruction, were providing inadequate ELL instruction in the Nogales Unified School District (Nogales), in violation of the Equal Educational Opportunities Act of 1974 (EEOA), which requires States to take "appropriate action to overcome language barriers" in schools. In 2000, the Federal District Court entered a declaratory judgment, finding an EEOA violation in Nogales because the amount of funding the State allocated for the special needs of ELL students (ELL incremental funding) was arbitrary and not related to the actual costs of ELL instruction in Nogales. The District Court subsequently extended relief statewide.
Defendants did not appeal any of the District Court's orders. In 2006, the state legislature passed HB 2064, which increased ELL incremental funding. The incremental funding increase required District Court approval. The Governor asked the state attorney general to move for accelerated consideration of the bill. The Speaker of the State House of Representatives and the President of the State Senate (Legislators) intervened and, with the superintendent, moved to purge the contempt order in light of HB 2064. In the alternative, they sought relief under Federal Rule of Civil Procedure 60(b)(5), which permits a party to seek relief from a judgment or order if a significant change either in factual conditions or in law renders continued enforcement detrimental to the public interest. The District Court denied their motion to purge the contempt order and declined to address the Rule 60(b)(5) claim. The Court of Appeals vacated and remanded for an evidentiary hearing on whether changed circumstances warranted Rule 60(b)(5). On remand, the District Court denied the Rule 60(b)(5) motion, holding that HB 2064 had not created an adequate funding system. The Court of Appeals affirmed the decision of the District Court and concluded that Nogales had not made sufficient progress in its ELL programming to warrant relief. Defendants petitioned for further review by the United States Supreme Court.
1. Did the petitioners (The Speaker of the State House of Representatives, the President of the State Senate and the Superintendent of Public Instruction) have legal standing to pursue the case?
2. Was Arizona in compliance with its statutory obligation by new means that reflected new policy insights and other changed circumstances?
2. Court remanded the case for factual determination.
1. The superintendent had legal standing. To establish Article III standing, a plaintiff must present an injury that is concrete, particularized, and actual or imminent; fairly traceable to the defendant's challenged action; and redressable by a favorable ruling. The Court observed that the following sufficed to show that the superintendent had legal standing. The Superintendent was a named defendant, the declaratory judgment held him in violation of the EEOA, and the injunction runs against him. Because the superintendent has standing, the Court need not consider whether the Legislators also have standing.
2. The Court reasoned that because the Court of Appeals and the District Court misperceived the obligation imposed by the EEOA and the breadth of the Rule 60(b)(5) inquiry, the cases were remanded for a proper examination of at least four factual and legal changes that may warrant relief. First, it should be determined whether Nogales' implementation of Structured English Immersion was a “changed circumstance" warranting relief. Second, an analysis should be conducted to ascertain whether the No Child Left Behind Act of 2001 represented a significant "changed circumstance." Third, an inquiry should be made as to whether, as a result of structural and managerial improvements, Nogales was providing equal educational opportunities to ELL students. Lastly, since there was an overall increase in education funding available in Nogales, a determination of whether the State's general education funding budget, in addition to local revenues, supported EEOA-compliant ELL programming in Nogales.
The Court reversed the decision of the Court of appeals and remanded the case for further proceedings.
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