Law School Case Brief
Matanuska-Susitna Borough Sch. Dist. v. State - 931 P.2d 391 (Alaska 1997)
Where there is no unequal treatment, there can be no violation of the right to equal protection of law. In the absence of any evidence of disparate treatment, there is no basis for an equal protection claim, and the court need not subject the challenged laws to sliding scale scrutiny.
The Matanuska-Susitna Borough (“Borough”), the Matanuska-Susitna School District (“District”), and several individual plaintiffs challenged Alaska public school funding laws, arguing that differences in treatment between regional educational attendance area (“REAA”) school districts and city and borough school districts, and among the non-REAA districts, violated their right to equal protection of the law under the state constitution. The borough and the taxpayers contended that under the sections, regional education attendance areas received 98 percent state funding for construction, while borough areas only received 70 percent state funding. The superior court dismissed the equal protection claims on summary judgment, awarded attorney's fees against the Borough and the District, and assessed costs against the Borough, the District, and the individual plaintiffs.
Did § 14.11.100, concerning state funding for school construction, and § 14.17.025, concerning local contribution for school construction, violate the equal protection rights of the borough and the taxpayers?
The Court found that the taxpayers did not prove that they had been disadvantaged somehow in relation to the taxpayers residing in the regional education attendance areas. The taxpayers qualified as public interest litigants, so they were be required to pay litigation costs. The borough was not a public interest litigant, so it was properly ordered to pay costs.
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