Board of Education, Joliet Township High School District No. 204 v. Board of Education, Lincoln Way Community High School District No. 210, 231 Ill. 2d 184

897 N.E.2d 756 (Ill. 2008) · Supreme Court of Illinois · October 17, 2008 · No. No. 105018

Summary

The Illinois Supreme Court considered whether Illinois School Code section 7-2b, governing detachment and annexation of school-district territory, was preempted by the federal Equal Educational Opportunities Act. The court held that the EEOA did not require the Illinois State Board of Education to adjudicate or consider the alleged segregative effects of a detachment/annexation petition. It reversed the appellate court and remanded the matter to the circuit court for consideration of the school district's EEOA claim.

Holdings

  1. The Equal Educational Opportunities Act does not require a state educational agency to conduct an affirmative predecision review or formal adjudication of the segregative effects of every detachment-and-annexation petition.
  2. Section 7-2b is not preempted by the EEOA because the state statutory framework does not prevent the federal claim from being heard and adjudicated by a competent court.
  3. The circuit court has original jurisdiction to hear and fully adjudicate District 204's EEOA claim as an independent action, including by receiving evidence and, where appropriate, granting injunctive relief.
  4. The ordinary forfeiture rule and the exclusivity of administrative review do not bar the EEOA claim because section 7-2b denied District 204 any opportunity to develop a record before the administrative agency.

Questions Presented

  1. Whether the Equal Educational Opportunities Act requires an educational agency to consider the segregative effects of a section 7-2b detachment-and-annexation petition before granting it.
  2. Whether section 7-2b of the Illinois School Code is preempted by the Equal Educational Opportunities Act because it bars the Illinois State Board of Education from considering the federal claim.
  3. Whether the circuit court may adjudicate District 204's Equal Educational Opportunities Act claim in an independent action under its original jurisdiction rather than solely through administrative review.
  4. Whether the claim was forfeited or barred by the exclusivity of administrative review when the administrative statute prohibited the Board from developing a factual record on the claim.

Disposition

reversed_and_remanded

Cases Cited (19)

  • Kinkel v. Cingular Wireless, LLC, 223 Ill. 2d 1, 15, 857 N.E.2d 250 (2006)(followed)
  • Schultz v. Northeast Illinois Regional Commuter R.R. Corp., 201 Ill. 2d 260, 288, 775 N.E.2d 964 (2002)(followed)
  • Harshman v. DePhillips, 218 Ill. 2d 482, 490, 844 N.E.2d 941 (2006)(followed)
  • Crosby v. National Foreign Trade Council, 530 U.S. 363, 372-73, 373, 388 (2000)(followed)
  • Lorillard Tobacco Co. v. Reilly, 533 U.S. 525, 540-41 (2001)(followed)
  • Fidelity Federal Savings & Loan Ass'n v. de la Cuesta, 458 U.S. 141, 153 (1982)(distinguished)
  • Hines v. Davidowitz, 312 U.S. 52, 67-68 (1941)(followed)
  • Gomez v. Illinois State Board of Education, 811 F.2d 1030, 1038 (7th Cir. 1987)(distinguished)
  • Howlett v. Rose, 496 U.S. 356, 369-73 (1990)(followed)
  • Delgado v. Board of Election Commissioners, 224 Ill. 2d 481, 485, 865 N.E.2d 183 (2007)(followed)

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