Campbell County School District v. State, 2008 WY 2

Summary

The Supreme Court of Wyoming held that the state's public-school finance and capital-construction funding system satisfied the Wyoming Constitution's thorough-and-efficient education requirement. The court addressed challenges concerning operations funding, recalibration of the cost-of-education model, teacher salaries, special-needs funding, and school facilities, while requiring certain adjustments. The court ended its retained jurisdiction over compliance with prior school-finance decisions.

Holdings

1. The State's operations-funding system, considered as a whole, satisfied Wyoming's constitutional requirement to provide a thorough and efficient education funded from statewide wealth, subject to specific corrections and implementation requirements identified by the court.
2. When the issue is whether revisions to a cost-based funding model accurately reflect the cost of education, the court reviews the district court's factual findings for clear error; strict scrutiny is not the appropriate test unless the funding difference is wealth-based.
3. The State's operation-and-maintenance funding approach did not violate the equal-protection clause of the Wyoming Constitution.
4. So long as Wyoming uses a cost-of-education model, regional cost-of-living adjustments may not reduce salaries below the statewide cost of hiring personnel established by the model. Adjustments must permit districts in higher-cost areas to attract and retain teachers and must recognize housing costs as a significant component of cost of living.
5. A historic-cost funding model must be adjusted for inflation so that its figures continue to represent the current cost of education, but the legislature is not required to use a particular inflation index.
6. The Wyoming Constitution does not require the State to fund voluntary preschool programs for children under age six.
7. Wyoming enacted a comprehensive and constitutional statutory plan for school capital construction funded from statewide wealth, although implementation deficiencies required case-by-case review of facilities.

Questions Presented

1. Whether Wyoming's revised cost-based operations-funding model complied with the constitutional mandates established in Campbell II.
2. Whether the State's operation-and-maintenance funding formula violated equal protection by limiting funded square footage.
3. Whether the State adequately funded at-risk students, vocational education, small schools, small districts, regional cost differences, and inflation.
4. Whether the Wyoming Constitution required the State to fund voluntary preschool programs.
5. Whether the statutory and regulatory capital-construction system was constitutional despite the State's failure to remedy all immediate-need facilities within the deadlines previously imposed.
6. Whether the challengers were entitled to reimbursement of alleged funding shortfalls or attorney fees.

Disposition

reversed_and_remanded