Law School Case Brief
Vergara v. State of Cal. - 246 Cal. App. 4th 619, 209 Cal. Rptr. 3d 532 (2016)
The constitutionality of a statute is a question of law, which the court reviews de novo. De novo review is also the general standard of review when a mixed question of law and fact implicates constitutional equal protection rights. Mixed questions of law and fact arise when historical facts are admitted or established, the rule of law is undisputed, and the issue is whether the facts satisfy the relevant statutory or constitutional standard, or to put it another way, whether the rule of law as applied to the established facts is or is not violated. De novo review is generally appropriate in such circumstances because usually the application of law to fact will require the consideration of legal concepts and involve the exercise of judgment about the values underlying legal principles. To the extent appellate review requires the court to analyze factual determinations based on evidence presented at trial, the court reviews the trial court's findings of fact for substantial evidence.
Plaintiffs B.V., a minor student, and several fellow students who attended California public schools, filed a lawsuit in California state court against defendants State of California and several state officials, seeking a court order declaring various provisions of the Education Code unconstitutional. According to the students, the challenged provisions, which governed how kindergarten through grade 12 public school teachers obtained tenure, how they were dismissed, and how they were laid off on the basis of seniority, violated the California Constitution's guarantee that all citizens enjoy the "equal protection of the laws." The matter went to trial. After hearing eight weeks of evidence, the trial court issued a ruling declaring five sections of the Education Code—sections 44929.21, subdivision (b), 44934, 44938, subdivision (b)(1) and (2), 44944, and 44955—unconstitutional and void. The State appealed the judgment.
Did the state statutes governing how kindergarten through grade 12 public school teachers obtained tenure, how they were dismissed, and how they were laid off on the basis of seniority violate the students' right to equal protection of the laws?
The Supreme Court of the United States held that tenure, dismissal, and reduction-in-force statutes that allegedly created an oversupply of grossly ineffective public school teachers were not shown to facially violate the equal protection rights of poor and minority students under Cal. Const., art. I, § 7, because there was no showing that the statutes inevitably caused the students to be provided with an education that was not basically equivalent to more affluent and/or white peers. Moreover, the Court held that the statutes did not address the assignment of teachers, and instead, the evidence was that teacher assignments were made by administrators, guided by teacher preference, district policies, and collective bargaining agreements. A subset of the general student population assigned to grossly ineffective teachers was not an identifiable class under equal protection analysis.
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