Summary
The Missouri Court of Appeals considered whether Missouri Revised Statutes section 167.131, requiring accredited school districts to accept transfer students from an unaccredited district, violated the Hancock Amendment. Relying on Breitenfeld v. School District of Clayton, the court held that the statute reallocates existing educational responsibilities rather than mandating a new or increased level of activity. The court reversed the judgment favoring taxpayers from three school districts, affirmed the judgment against the Blue Springs and Raytown taxpayers, and reversed the related attorney’s-fee award.
Topics
Practice areas
Questions Presented
- Whether section 167.131 mandates a new or increased level of activity in violation of the Hancock Amendment.
- Whether the Hancock Amendment requires a district-by-district inquiry into the costs incurred by receiving school districts.
- Whether the State was judicially estopped from arguing that section 167.131 did not impose a new or increased level of activity based on stipulations made in the trial court.
- Whether the trial court’s award of attorney’s fees could stand after reversal of the Hancock Amendment judgment.
Holdings
- Section 167.131 does not mandate a new or increased level of activity; it reallocates among school districts the responsibility for educating students who reside in unaccredited districts.
- The Hancock Amendment does not prohibit the reallocation of existing statewide educational activities among local entities under section 167.131, whether considered statewide or district by district.
- The State was not judicially estopped from arguing that section 167.131 did not mandate a new or increased level of activity, and a party cannot by stipulation bind a court to an erroneous interpretation of law.
- The attorney’s-fee award must be reversed because the judgment establishing a Hancock Amendment violation was reversed.
Key quotations
“This Court recently and unanimously held in Breitenfeld, 399 S.W.3d at 828-32, that section 167.131 does not impose an unfunded mandate in violation of the Hancock Amendment.” (415 S.W.3d at 114)
“This is simply an increase in the frequency of providing the same service and is not a violation of the Hancock Amendment any more than would be the obligation to educate new students moving into a district each year.” (415 S.W.3d at 114)
“A Hancock Amendment violation requires both that a law mandate a new or increased level of activity and that it result in more than de minimus increased costs to the local entity.” (415 S.W.3d at 115)
“The trial court’s judgment granting relief to the Independence, Lee’s Summit, and North Kansas City school districts and awarding attorney’s fees is reversed. In all other respects the judgment is affirmed.” (415 S.W.3d at 116)
Factual background
The Missouri State Board of Education classified Kansas City Public Schools as unaccredited effective January 1, 2012. Under section 167.131, students residing in an unaccredited district could transfer to accredited public schools in the same or an adjoining county, with the sending district required to pay tuition and provide transportation. Taxpayers from five accredited districts contended that requiring their districts to accept transfer students created a new or increased level of activity without full state funding, violating the Hancock Amendment.
Procedural history
Taxpayers from five accredited school districts sued the State of Missouri and Kansas City Public Schools, seeking declaratory and injunctive relief against the student-transfer requirements of section 167.131. The trial court held that the statute imposed a new activity on receiving districts, but found a Hancock Amendment violation only where reimbursement was insufficient to cover estimated costs; it awarded attorney’s fees to the successful taxpayers. The appellate court reversed the judgment in favor of the Independence, Lee’s Summit, and North Kansas City taxpayers and affirmed the judgment against the Blue Springs and Raytown taxpayers.