Case Challenging Segregation As a Violation of State Right to Education Heading to Minnesota Supreme Court
On Monday, the Minnesota Court of Appeals in Cruz-Guzman v. Minnesota ruled that plaintiffs' challenge to segregation in public schools was non-justiciable under the state constitution. Plaintiffs, among other claims, argued that segregated schools deprive students of an adequate education. While the court recognized that the state has a duty to provide a uniform, thorough, and efficient education under the state constitution, the court reasoned that the constitution does not include any qualitative standards or judicially manageable standards. Thus, it lacked a basis upon which to find that segregation did not or did not deprive students of the requisite level of education. The court wrote:
Appellants argue that the Minnesota Constitution does not provide textual support for respondents’ assertion of a constitutional right to an “adequate” education. As appellants note, “[T]he word ‘adequate’ does not appear in Minnesota’s Education Clause.” Instead, the Education Clause sets forth the legislature’s duty to establish a “general and uniform system of public schools” and to secure, “by taxation or otherwise,” a “thorough and efficient system of public schools.” Minn. Const. art. XIII, § 1. The clause does not state that the legislature must provide an education that meets a certain qualitative standard. Moreover, assuming without deciding that the Education Clause requires the provision of
an education of a certain quality, the clause does not set forth the relevant qualitative standard.
an education of a certain quality, the clause does not set forth the relevant qualitative standard.
Respondents’ request for relief therefore requires the judiciary to both read an adequacy requirement based on a qualitative standard into the language of the Education Clause and to defineEducation Law Prof Blog: