Sheff v. O'Neill - 238 Conn. 1, 678 A.2d 1267 (1996)

Rule:

Conn. Const. art. VIII, § 1, and art. I, §§ 1 and 20, impose on the legislature an affirmative constitutional obligation to provide schoolchildren throughout the state with a substantially equal educational opportunity. It follows that, if the legislature fails, for whatever reason, to take action to remedy substantial inequalities in the educational opportunities that such children are being afforded, its actions and its omissions constitute state action.

Facts:

Plaintiffs instituted the present suit under Conn. Const. art. I, §§ 1 and 20, and art. VIII, § 1, alleging that students in the Hartford public schools were burdened by severe educational disadvantages arising out of their racial and ethnic isolation and their socioeconomic deprivation. Seeking declaratory and injunctive relief, each count of the plaintiffs’ complaint was grounded on the proposition that the defendants have failed to fulfill their state constitutional responsibility to remedy these severe educational disadvantages. According to the plaintiffs, the de facto racial segregation deprived them of an education equal to those of schoolchildren living in other school districts. The trial court denied the defendants' motions to strike the complaint and for summary judgment. After an evidentiary hearing, the court concluded, however, that the plaintiffs had failed to prove that state action existed under the facts and circumstances of the case, and rendered judgment in favor of the defendants. Plaintiffs appealed. 

Issue:

1. Did the plaintiffs fail to prove that state action existed under the facts and circumstances of the case? 
2. Did the plaintiffs state a case for relief under the state’s constitution? 

Answer:

1) No. 2) Yes.

Conclusion:

The court found the question justiciable and held that state action, in terms of failing to remedy the inequalities, brought the public officials within the purview of the court. The court next found that Conn. Const. art. VIII, § 1, and art. I, §§ 1 and 20, imposed on the legislature an affirmative constitutional obligation to provide the minority schoolchildren with an educational opportunity substantially equal to that enjoyed by other schoolchildren and that this obligation exceeded any based on the federal constitution. The court found that the initiatives undertaken by the public officials had not eradicated the significant disparities between school districts. The court granted the minority schoolchildren declaratory judgment on their claims but directed the trial court to retain jurisdiction to grant consequential relief, if needed, thus giving the public officials time to fashion their own remedy.