Haridopolos v. Citizens for Strong Schools, Inc.
2011 Fla. App. LEXIS 18738, 2011 WL 7637788, 81 So. 3d 465 (2011)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A claim alleging the state has failed to meet its constitutional duty under Article IX, Section 1(a) of the Florida Constitution to provide a "uniform, efficient, safe, secure, and high quality system of free public schools" is not necessarily a nonjusticiable political question, and circuit courts have subject matter jurisdiction to hear such claims for declaratory relief.
Facts:
- Florida's Constitution, under Article IX, Section 1(a), establishes that education is a 'fundamental value' and a 'paramount duty' of the state.
- The constitutional provision requires the state to make adequate provision by law for a 'uniform, efficient, safe, secure, and high quality system of free public schools.'
- Two not-for-profit corporations, along with several students and their parents, alleged that the state of Florida was failing to meet this constitutional duty.
- The group claimed the state provided insufficient funding for public education, leading to inadequate teacher salaries and other resources.
- They further alleged that the state's accountability policies were an obstacle to high-quality education.
- As evidence of the system's failure, they pointed to schools that were not safe and secure, low graduation rates, and poor results on achievement tests.
Procedural Posture:
- A coalition of non-profits, students, and parents (Respondents) filed an amended complaint for declaratory relief against state officials (Petitioners) in the Leon County Circuit Court (a state trial court).
- The complaint alleged that the state failed to comply with its duty to provide an adequate public education system under Article IX, Section 1(a) of the Florida Constitution.
- The Petitioners filed a motion to dismiss the complaint, arguing that the claim presented a nonjusticiable political question over which the court lacked subject matter jurisdiction.
- The circuit court denied the Petitioners' motion to dismiss.
- The Petitioners then filed a petition for a writ of prohibition with the First District Court of Appeal of Florida, seeking an order to stop the trial court from proceeding with the case.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the political question doctrine deprive a circuit court of subject matter jurisdiction to hear a claim for declaratory relief alleging the state has violated its duty under Article IX, Section 1(a) of the Florida Constitution to provide a 'uniform, efficient, safe, secure, and high quality' public school system?
Opinions:
Majority - Benton, C.J.
No. The political question doctrine does not deprive the circuit court of jurisdiction because the Florida Constitution provides judicially ascertainable standards to measure the adequacy of public education. A writ of prohibition is an extraordinary remedy reserved for clear cases where a lower court usurps jurisdiction, not for correcting potential errors. The circuit court, as a court of general jurisdiction, is empowered to hear claims for declaratory judgment. Crucially, a 1998 amendment to Article IX, Section 1(a) added the terms 'efficient, safe, secure, and high quality' in direct response to the Supreme Court's decision in Coalition v. Chiles, which had found the prior language nonjusticiable. The Florida Supreme Court itself in Bush v. Holmes recognized that this amendment was intended to 'provide constitutional standards to measure the “adequacy” provision.' Therefore, the trial court has jurisdiction to proceed and determine whether, on the merits, the state has complied with its constitutional mandate.
Dissenting - Roberts, J.
Yes. The political question doctrine deprives the court of jurisdiction because the claim presents a nonjusticiable issue that is constitutionally committed to the legislative branch. This case is functionally identical to Coalition v. Chiles, where the Florida Supreme Court found the issue of educational 'adequacy' to be a political question. The terms added in the 1998 amendment—'efficient, safe, secure, and high quality'—are adjectives of degree that lack judicially manageable standards. Allowing this case to proceed would force the judiciary to make policy judgments about appropriations and educational strategies, which is a direct violation of the separation of powers. The relief respondents seek, including a 'remedial plan' and funding studies, confirms that they are asking the court to unconstitutionally usurp legislative power.
Concurring - Wolf, J.
No, the writ should be denied, but on narrower grounds. While the constitutional provision is likely not self-executing because its language directs that provision 'shall be made by law,' the judiciary is not powerless if the Legislature fails to act. If the Legislature ignores its constitutional directive to implement the public's will over a reasonable period, courts possess the power to fashion guidelines or compel the enactment of implementing legislation with measurable standards, as established in Dade County Classroom Teachers Ass’n, Inc. v. Legislature. The complaint's allegations, if true, indicate such a failure, giving the trial court jurisdiction to at least consider this type of remedy.
Analysis:
This decision significantly altered the legal landscape for educational adequacy lawsuits in Florida by distinguishing and moving past the precedent set in Coalition v. Chiles. By holding that the 1998 constitutional amendment provided justiciable standards, the court opened the door for judicial review of legislative policy and funding for public education. The ruling empowered trial courts to hear complex, evidence-intensive cases challenging the state's entire educational system, potentially leading to court-mandated reforms. The majority's decision, while denying the extraordinary writ of prohibition, set the stage for a definitive showdown at the Florida Supreme Court by certifying the core question of justiciability, highlighting the profound separation of powers implications at stake.
Unlock the full brief for Haridopolos v. Citizens for Strong Schools, Inc.