Richland County School District 2 v. Lucas

Summary

The South Carolina Supreme Court held that Appropriations Act Provisos 1.108 and 1.103 are constitutional. Proviso 1.108 prohibits K-12 public schools from using funds appropriated or authorized under the Act to announce or enforce mask mandates, while Proviso 1.103 governs funding for virtual education exceeding a specified enrollment threshold. The court rejected challenges based on the one-subject rule, local authority, equal protection, and the constitutional right to a free public education, and declined to issue advisory guidance.

Holdings

1. Proviso 1.108 is constitutional, complies with the one-subject rule, does not violate the Home Rule Act, and preempts conflicting local mask ordinances.
2. Proviso 1.108 prohibits the school district from using funds appropriated or authorized under the 2021-2022 Appropriations Act to announce or enforce a mask mandate in its K-12 schools; the court did not reject the possibility that other funds could be used for those purposes.
3. Proviso 1.103 is constitutional and does not deprive students of their constitutional right to a free public education.
4. The equal protection challenge fails because petitioners did not show that similarly situated students received disparate treatment, and the provisos apply equally to all students and public K-12 schools.
5. The court lacked authority to issue advisory guidance concerning the school district's options and obligations regarding facemasks and virtual education.

Questions Presented

1. Whether Provisos 1.108 and 1.103 violated the South Carolina Constitution's one-subject rule.
2. Whether Proviso 1.108 permitted a school district to implement and enforce a mask mandate using funds other than those appropriated or authorized by the 2021-2022 Appropriations Act.
3. Whether Provisos 1.108 and 1.103 improperly invaded the authority of local school boards or conflicted with local mask ordinances.
4. Whether Provisos 1.108 and 1.103 denied students equal protection of the law.
5. Whether Provisos 1.108 and 1.103 violated students' constitutional right to a free public education.
6. Whether the court had authority to provide advisory guidance concerning the school district's options and obligations regarding masks and virtual education.

Disposition

other