McDuffy v. Secretary of the Executive Office of Education
415 Mass. 545, 615 N.E.2d 516 (1993)
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Rule of Law:
Part II, c. 5, § 2 of the Massachusetts Constitution imposes a mandatory, enforceable duty on the Commonwealth's legislative and executive branches to provide an education for all its children. This duty is not merely aspirational but is a fundamental, judicially enforceable obligation of the state government.
Facts:
- The Commonwealth of Massachusetts's system for funding public elementary and secondary schools relied heavily on local property taxes.
- This funding mechanism resulted in significant disparities in per-pupil expenditures and educational resources between municipalities with high property values and those with low property values.
- Sixteen students, the plaintiffs, attended public schools in less affluent communities, including Brockton, Winchendon, Leicester, and Lowell.
- The schools in the plaintiffs' districts suffered from conditions such as crowded classes, reductions in staff, inadequate teaching in basic subjects, neglected libraries, and an inability to attract and retain high-quality teachers.
- In contrast, 'comparison' school districts in wealthier communities like Brookline, Concord, and Wellesley offered their students significantly greater educational opportunities, including multifaceted reading programs, thorough computer instruction, extensive teacher training, and a wide variety of courses.
- The Commonwealth provided state aid to supplement local funds, but the plaintiffs alleged this aid was insufficient to compensate for deficiencies in local funding capacity and was unpredictable from year to year.
- There was no state requirement that municipalities contribute a specific amount of local funds to their schools or that they use state educational aid exclusively for educational purposes.
Procedural Posture:
- An initial suit, Webby v. Dukakis, was filed in May 1978 in the Supreme Judicial Court for Suffolk County.
- The case lay dormant for several years following legislative changes to school funding in 1978 and 1985.
- In 1990, plaintiffs filed a 'restated complaint' under the caption McDuffy v. Robertson.
- A separate but similar suit, Levy v. Dukakis, was filed in the Superior Court Department in 1989.
- A single justice of the Supreme Judicial Court transferred the relevant counts of the Levy complaint to be heard with the McDuffy case.
- The parties filed a stipulation of agreed facts in 1991 and a supplemental stipulation in 1992.
- In December 1992, a single justice reserved and reported both cases without decision to the full bench of the Supreme Judicial Court to be decided on the stipulated record.
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Issue:
Does Part II, c. 5, § 2 of the Massachusetts Constitution, which states that it is the 'duty of legislatures and magistrates... to cherish... public schools,' impose an enforceable duty on the Commonwealth to provide an adequate education to all public school children, regardless of the wealth of their local community?
Opinions:
Majority - Liacos, C.J.
Yes, Part II, c. 5, § 2 imposes an enforceable duty on the Commonwealth to provide an education for all its children, a duty that the Commonwealth is currently failing to fulfill. The court's reasoning is based on a detailed analysis of the Constitution's text, structure, and historical context. The 18th-century meaning of 'duty' was an 'obligation,' and 'cherish' meant 'to support' or 'nurture,' making the clause a mandatory command, not a mere aspiration. The framers, particularly John Adams, and the people who ratified the Constitution in 1780 understood this provision as essential for the preservation of a republican government, requiring an educated citizenry. Based on the stipulated record, which details the gross inadequacies in the plaintiffs' schools compared to those in wealthier districts, the court concludes that the Commonwealth's financing system fails to provide children in less affluent communities with their constitutionally-guaranteed education.
Concurrence - O'Connor, J.
Yes, the Constitution imposes a duty to provide an education, but the record is insufficient to prove the Commonwealth has failed to meet it. This opinion agrees with the majority that Part II, c. 5, § 2 creates an enforceable duty. However, it dissents from the conclusion that a constitutional violation has been proven. The concurrence argues that while the parties stipulated to the existence of various reports and expert opinions detailing inadequacies, they did not stipulate to the truth or validity of those opinions. The fact that wealthier districts offer 'significantly greater educational opportunities' does not, by itself, prove that poorer districts are providing a constitutionally 'inadequate' education. Therefore, the plaintiffs have failed to meet their burden of proof.
Analysis:
This landmark decision fundamentally reinterpreted the 'education clause' of the Massachusetts Constitution, transforming it from a perceived hortatory statement into a judicially enforceable, affirmative duty of the state. By holding the Commonwealth—not just local municipalities—ultimately responsible for the quality of public education, the ruling established a new legal basis for challenging inequities in school funding. This precedent empowers courts to oversee educational policy and finance, compelling the legislative and executive branches to devise a system that ensures an adequate education for all students, regardless of the wealth of their community. The decision significantly altered the landscape of education law in Massachusetts, paving the way for major legislative reforms in school finance.
