Lake View School District No. 25 v. Huckabee, 351 Ark. 31

Summary

The Supreme Court of Arkansas affirmed that the state's public school-funding system violated the Arkansas Constitution's Education Article and equality provisions. The court reversed the trial court's treatment of excess debt service as a credit against the uniform millage rate and reduced the attorneys' fee award to $3,088,050 plus $309,000 in costs. The court also rejected the argument that the constitutionality of school funding was a nonjusticiable political question.

Holdings

1. The constitutionality of Arkansas's school-funding system is justiciable; deciding whether the system complies with the Arkansas Constitution does not improperly usurp legislative or executive functions.
2. Arkansas's post-1994 school-funding system violated article 14, section 1 of the Arkansas Constitution because the State failed to fulfill its absolute constitutional duty to provide a general, suitable, and efficient system of free public schools.
3. The school-funding system violated article 2, sections 2, 3, and 18 of the Arkansas Constitution because it produced unequal educational opportunities among school districts based on wealth, and the State offered no rational basis for the disparities.
4. The trial court lacked authority to order the State to implement state-provided early-childhood education, and article 14, section 1 does not itself mandate public education for children under six.
5. Arkansas Code section 26-80-204(18)(C), which permitted excess debt-service millage to be credited against the uniform 25-mill rate, violated Amendment 74 to the Arkansas Constitution.
6. The trial court abused its discretion by using a percentage of an asserted economic benefit and a multiplier, but attorneys' fees based on 20,587 hours at $150 per hour and costs of $309,000 were appropriate.

Questions Presented

1. Whether challenges to Arkansas's public-school funding system presented a justiciable controversy rather than a nonjusticiable political question.
2. Whether the post-1994 school-funding system violated Article 14, section 1 of the Arkansas Constitution by failing to provide a general, suitable, and efficient system of free public schools.
3. Whether the funding system violated the equality provisions of article 2, sections 2, 3, and 18 of the Arkansas Constitution by permitting unequal educational opportunities based on district wealth.
4. Whether the trial court could require state-provided early-childhood education as part of the remedy.
5. Whether excess debt-service millage could be credited against the uniform 25-mill tax required by Amendment 74.
6. Whether the trial court properly awarded attorneys' fees and costs.

Disposition

other