Summary
The Kansas Supreme Court determined that Substitute for House Bill 2001 restored a supplemental general state aid formula previously approved as constitutionally compliant. The court concluded that the equity issues in the Gannon litigation were presently resolved and that no judicial remedy was necessary at that time, while retaining jurisdiction over the case and the adequacy issues.
Topics
Practice areas
Questions Presented
- Whether Substitute for House Bill 2001 brought the supplemental general state aid formula into compliance with the equity requirement of Article 6, section 6 of the Kansas Constitution.
- Whether the equity issues remaining after the court's prior school-funding decisions were presently resolved and required a judicial remedy.
Holdings
- Substitute for House Bill 2001 revived the previously approved supplemental general state aid formula, and its planned implementation with full funding for fiscal year 2017 would comply with the equity component of Article 6, section 6 of the Kansas Constitution.
- The equity issues on appeal were presently resolved, the legislature had satisfied the court's prior equity-related orders, and no judicial remedy was necessary at that time.
Factual background
Kansas's legislature enacted Substitute for House Bill 2001 after the court's prior decisions found inequities in the local option budget and supplemental general state aid portions of the K-12 public-school funding system. The governor signed the legislation on June 27, 2016, with an effective date of July 1, 2016. The parties then filed a joint stipulation asserting that the legislation satisfied the court's prior equity orders and that no judicial remedy was currently necessary.
Procedural history
The court had previously held that Kansas legislation failed to cure inequities in the local option budget and supplemental general state aid components of the state's school-funding system. The legislature enacted Substitute for House Bill 2001 during a special session, and the parties jointly stipulated that the legislation satisfied the court's prior equity-related orders. The court reviewed the stipulation, legislative history, and appellate record, concluded that the equity issues were presently resolved, declined to order a remedy, retained jurisdiction, and reserved adequacy issues for later proceedings.