Oklahoma Educ. Assoc. v. Okla., No. 103,702 (Okla. May 8, 2007)
The Oklahoma Supreme Court has affirmed the dismissal of a suit brought by the Oklahoma Education Association (OEA) against the State of Oklahoma challenging the state's school funding scheme. The high court ruled that OEA lacked legal standing to assert claims of injury to Oklahoma students, school districts, or OEA members. More importantly, the court also ruled that the question of the adequacy of the state's school funding scheme is a non-justiciable political question. OEA's suit had alleged that the state legislature has underfunded the state's public schools. The lower court dismissed the case in an oral ruling, agreeing with the state that the suit raised a political question over which the court lacked jurisdiction.
Addressing the issue of legal, the supreme court found that OEA had failed to established that any of its members are Oklahoma students. As a result, OEA failed to meet its burden of showing any of its member have a right of their own to assert injury to the rights of Oklahoma's students. As for the standing of the school districts and OEA members, the high court found that they had failed to point to a specific constitutional provision that imposed a duty on them to provide students with a uniform, adequate education. As a result, the court concluded the school districts and OEA members had failed to demonstrate they have an "interest which is within a constitutionally protected zone." Although the court had disposed of the case on the ground of standing, it went on to consider whether the suit raised a non-justiciable political question that should be left to the legislative branch in order to preserve the constitutional principle of separation of powers. Based on its interpretation of the applicable state constitution provisions, the court determined that the legislature's "exclusive authority to declare the fiscal policy of Oklahoma is limited only by constitutional prohibitions." OEA had failed to provide the court with any applicable limitations, the court found, concluding that the "plaintiffs are attempting to circumvent the legislative process by having this Court interfere with and control the Legislature's domain of making fiscal-policy decisions and of setting educational policy by imposing mandates on the Legislature and by continuing to monitor and oversee the Legislature."
Oklahoma Educ. Assoc. v. Okla., No. 103,702 (Okla. May 8, 2007)
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[Editor's Note: For background suit, including the lower court decision, see below. This opinion is one of the few to reach this conclusion on the question of justiciability. For example, the Arizona appellate court decision described at the second link below, on which that state's supreme court has declined to rule, specifically rejected a lower court ruling that the matter was non-justiciable but found for the state on other grounds. More information on justiciability in finance adequacy cases, including an amicus brief by NSBA and others to Maryland's high court on this question, is available starting from the third link.]
[NSBA School Law pages on OEA v. Okla.]
[NSBA School Law pages on Crane v. Ariz.]
[NSBA School Law pages on Columbia Falls Elem. Sch. Dist. No. 6 v. Mont.]