Summary
The Supreme Court of South Dakota considered a challenge to the constitutionality of the state's public-school funding system under Article VIII, Sections 1 and 15 of the South Dakota Constitution. The court held that the Constitution guarantees South Dakota children a free, adequate, and quality public education, including an opportunity to prepare for their future roles as citizens and competitors economically and intellectually. The opinion addresses the burden of proof, standard of review, and the state's school-funding formula.
Holdings
- Article VIII of the South Dakota Constitution guarantees all South Dakota children a free, adequate, and quality public education that provides an opportunity to prepare for their future roles as citizens, participants in the political system, and economic and intellectual competitors.
- The plaintiffs failed to prove that South Dakota's school-funding system, as it existed at the time of trial, was unconstitutional.
- The school-funding challenge was justiciable; the court had authority to interpret and enforce the South Dakota Constitution even though the dispute implicated legislative education and funding decisions.
Questions Presented
- Whether Article VIII, sections 1 and 15 of the South Dakota Constitution guarantee all South Dakota children a free, adequate, and quality public education.
- Whether South Dakota's statutory public-school funding system violated those constitutional provisions because it failed to provide an adequate and quality education or was not sufficiently related to actual educational costs and student achievement.
- Whether challenges to the adequacy and constitutionality of the school-funding system presented a nonjusticiable political question.
- Whether the plaintiffs overcame the presumption that the legislative funding scheme was constitutional.
Disposition
affirmed
Cases Cited (20)
- Brendtro v. Nelson, 2006 S.D. 71, 720 N.W.2d 670(followed)
- People in Interest of Z.B., 2008 S.D. 108, 757 N.W.2d 595(followed)
- Green v. Siegel, Barnett & Schutz, 1996 S.D. 146, 557 N.W.2d 396(followed)
- South Dakota Ass'n of Tobacco & Candy Distributors v. State ex rel. Department of Revenue, 280 N.W.2d 662 (S.D. 1979)(followed)
- Hubbard v. City of Pierre, 2010 S.D. 55, 784 N.W.2d 499(followed)
- Estate of Dimond, 2008 S.D. 131, 759 N.W.2d 534(followed)
- State v. Dillon, 2010 S.D. 72, 788 N.W.2d 360(followed)
- Olson v. Guindon, 2009 S.D. 63, 771 N.W.2d 318(followed)
- Campbell County School District v. State, 907 P.2d 1238 (Wyo. 1995)(distinguished)
- State v. Campbell County School District, 19 P.3d 518 (Wyo. 2001)(followed in part)
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