The Colorado Supreme Court ruled today on public school financing in People v. Lobato, summarizing the case on its website in the following way:
"The Supreme Court held that the public school financing system complies with the Colorado Constitution, because it is rationally related to the constitutional mandate that the General Assembly provide a 'thorough and uniform' system of public education. It also affords local school districts control over locally raised funds and therefore over 'instruction in the public schools.' Accordingly, the Court reversed the trial court’s finding that the public school financing system is unconstitutional."
Plaintiff Anthony Lobato (on behalf of his then minor child) initiated an action for declaratory relief in 2005. Mr. Lobato claimed that Colorado's school financing system violated the "thorough and uniform" mandate in the Education Clause of the Colorado Constitution. Colo. Const. Art. IX, 2. Mr. Lobato's complaint centered on the argument that certain rural local school districts' "lack of sufficient financial resources, coupled with the public school financing system’s restrictions on spending, prevents the districts from exerting meaningful control over educational instruction and quality.”
The state of Colorado moved the trial court to dismiss the action and the motion was granted without taking any evidence based on a lack of standing argument. Mr. Lobato appealed the dismissal to the Colorado Appeals Court, which upheld the dismissal. Mr. Lobato then petitioned the Colorado Supreme Court to review the standing question. The Colorado Supreme Court held that the question of whether school financing was rationally related to constitutional mandates did not infringe upon the legislature’s policymaking authority. Therefore, it found that Mr. Lobato had standing and the Supreme Court remanded the case back to trial. This decision is hereinafter referred to as Lobato I.
At trial, Mr. Lobato put on evidence that there was no rational relation between the public school finance system and Colorado’s Constitutional mandate for a thorough and uniform education system. The trial court ruled in Mr. Lobato’s favor and enjoined the state from continuing to act under the current public school finance system. The state appealed straight to the Colorado Supreme Court, which agreed to consider the following issues:
1) Whether Mr. Lobato’s claims presented an nonjusticiable political question;
2) Whether the public school financing system satisfies the rational basis test articulated in earlier case law and conforms with the Education Clause; and
3) Whether the current public school financing system violated the Local Control Clause of the Colorado Constitution.
The Colorado Supreme Court held that its decision in Lobato I still controlled the justiciability question and that, since there had been no appreciable change in the circumstances surrounding this issue, the case was still justiciable.
The Colorado Supreme Court next analyzed the rational behind the current public school financing system to determine whether it conformed to the “thorough and uniform” mandate of the Education Clause of the Colorado Constitution. The Court found that public school finance system met this mandate because it “incorporates enrollment numbers, a per-pupil base amount of money, and applicable statutory factors to calculate an amount of money each district will receive in a given year from a combination of state and local sources.” This system, the Court held, “funds a system of free public schools that is of a quality marked by completeness, is comprehensive, and is consistent across the state.”
Finally, the Colorado Supreme Court analyzed the question of whether this system violated the Local Control Clause of the Colorado Constitution. The Court held that they system did not violate the Local Control Clause, because it allowed local districts to maintain control over any locally raised public school funding.
To read a full copy of this opinion please visit the Colorado Bar Association's website, here.