Leandro v. State - 346 N.C. 336, 488 S.E.2d 249 (1997)

Rule:

The state legislature, under N.C. Const. art. IX, § 2(1), has the duty of providing the children of every school district with access to a sound basic education. It has inherent power to do those things reasonably related to meeting that constitutionally prescribed duty. This power includes the power to create a supplemental state funding program that has as its purpose the provision of additional state funds to poor districts so that they can provide their students access to a sound basic education. However, a funding system that distributes state funds to the districts in an arbitrary and capricious manner unrelated to such educational objectives would not be a valid exercise of that constitutional authority and could result in a denial of equal protection or due process.

Facts:

Education boards, students, and their parents or guardians from poor school systems filed suit against the state and its Board of Education, alleging that they have a right to adequate educational opportunities which is being denied them by defendants under the current school funding system.  According to the plaintiffs, children in their poor school districts were not receiving a sufficient education to meet the minimal standard for a constitutionally adequate education. Plaintiffs further alleged that children in their districts were denied an equal education because there was a great disparity between the educational opportunities available to children in their districts and those offered in more wealthy districts of our state. Education boards, students, and their parents or guardians from wealthy urban schools intervened alleging that their educational needs were also being inadequately considered. According to the plaintiff-intervenors, the State of North Carolina and the State Board of Education have violated the North Carolina Constitution and chapter 115C of the North Carolina General Statutes by failing to ensure that their relatively wealthy school districts have sufficient resources to provide all of their students with adequate and equal educational opportunities. In response to plaintiffs' and plaintiff-intervenors' complaints seeking declaratory and other relief, defendants filed a motion to dismiss under N.C.G.S. § 1A-1, Rule 12(b)(1), (2), and (6), asserting that the trial court lacked subject matter and personal jurisdiction and that plaintiff-parties had failed to state any claim upon which relief could be granted. The trial court denied the motion to dismiss, which the appellate court reversed. According to the appellate court, the right to education guaranteed by the North Carolina Constitution was limited to one of equal access to the existing system of education and does not embrace a qualitative standard. The plaintiffs appealed.

Issue:

Under the circumstances, was the appellate court’s decision to dismiss the plaintiffs’ complaint justified? 

Answer:

No.

Conclusion:

The Court held that the state's constitution guaranteed the right to a free public education, required that an education prepare students to participate and compete in the society or the education was inadequate, and guaranteed the opportunity to receive a sound basic education. The Court averred that N.C. Const. art. IX, § 2(1) did not require substantially equal funding or equal advantages, and did not guarantee a right to equal educational opportunities in the various school districts of the state. The court held that sufficient allegations were made regarding the state's supplemental funding system and violations of N.C. Gen. Stat. § 115C to justify further proceedings. However, in the case at bar, the Court noted that the plaintiffs’ allegations that the current school funding system violated portions of N.C.G.S. §§ 115C-1, 115C-81(a1), 115C-122(3), and 115C-408(b) stated a claim upon which relief may be granted if they were supported by substantial evidence that the alleged violations of chapter 115C have occurred and that those violations have deprived children of some school districts of the opportunity to receive a sound basic education. Moreover, plaintiff-intervenors have made sufficient allegations in their complaint to entitle them to proceed to attempt to prove that the state supplemental funding system was unrelated to legitimate educational objectives and, therefore, was arbitrary and capricious where they alleged that their relatively wealthy urban districts have been denied equal protection of the laws because they have greater numbers of students requiring special education programs than other districts, and the current funding system did not take into consideration the amount of money required to educate particular students with special needs. Accordingly, the Court remanded the case for the appellate court for further remand to the trial court for further proceedings.