King v. State: A lot to digest

by Ryan Koopmans | April 22, 2012

By Ryan Koopmans

Last Friday, a majority of the Iowa Supreme Court rejected a constitutional challenge to Iowa’s public education system.  The case is noteworthy for that ruling alone–especially this year ,when education reform is at the top of the legislative agenda.  But the five separate opinions–totaling 163 pages–are about much more than education.  Several issues surfaced in this case, chief among them constitutional interpretation and the role of the judiciary.  The justices also wrangled over the proper application of the rational-basis test, issue preservation, and the pleading requirements applicable to a motion to dismiss.  One posts isn’t enough to cover all of this, so I’ll go in stages–starting first with a general overview of the case.

The plaintiffs–several students and their parents–sued the State, the Department of Education, the head of the Department, and Governor Culver, claiming that they weren’t doing enough to service Iowa’s largest and smallest school districts.  The plaintiffs didn’t claim that the schools were underfunded; rather they faulted the defendants for giving too much control to the local school districts and for not implementing statewide academic standards.  As a result, the plaintiffs claimed that the defendants violated the education, equal protection, and due process clauses of the Iowa Constitution, as well as Iowa’s education statute.

In 2008, Polk County District Court Judge Karen Romano dismissed the entire lawsuit, ruling that the claims were nonjusticiable political questions.  The case was briefed and then argued to the Iowa Supreme Court on in March 2010, and then reargued in June 2011 after Justices Waterman, Mansfield, and Zager joined the Court.

By a vote of 4-3, the Iowa Supreme Court affirmed the dismissal of the lawsuit–although not on political question grounds.  Justice Mansfield, joined by Chief Justice Cady and Justices Waterman and Zager, reached the merits of the lawsuit and held that the plaintiffs’ criticisms of the Iowa’s education policy, even if true, do not amount to a violation of Iowa’s education clause.  The majority also ruled that the plaintiffs’ equal protection and due process claims failed because there was a conceivable rational basis for not establishing greater statewide standards–namely, that “[t]he legislature may have decided that local school board autonomy is preferable in certain instances to state mandates.”  Moreover, the plaintiffs didn’t claim that the State treats school districts differently from one another (i.e., unequally); they claimed only that the State should be more active in regulating those school districts.  That, said the majority, does not amount to a violation of the equal protection clause.

The majority also questioned whether the State can ever violate substantive due process by failing to act.  The plaintiffs alleged that the State was not doing enough to regulate schools, not that it was taking some wrongful affirmative action.  As the majority notes, that’s an unusual due drocess claim.  The due process clause of the Iowa Constitution, like the U.S. Constitution, provides that “no person shall be deprived of life, liberty, or property, without due process of law.”  Normally, the right to liberty is associated with the right to be left alone–to live one’s life without government intrusion.  The plaintiffs in this case argued the opposite–that the State government should have injected itself into school governance to a greater degree.   The majority expressed “serious doubt” whether such a claim would ever have merit, but it nonetheless left the issue open because the State’s “inaction” survived rational basis review.

Finally, the majority held that Iowa Code Section 256.37–which provides, among other things, that “[i]t is the policy of the state of Iowa to provide an education system that prepares children of this state to meet and exceed the technological, informational, and communications demands of our society”–does not contain a private right of action, and therefore the plaintiffs’ claim failed on the face of the petition.

Justices Wiggins, Appel, and Hecht dissented, with Wiggins and Appel each writing separate opinions.  The three justices believe the plaintiffs’ claims are justiciable and that the  judgment should be reversed and the case remanded to the district court for further proceedings.  Justice Wiggins, joined by Justices Appel and Hecht, faulted the majority (which Justice Wiggins refers to as a plurality) for reaching the merits of the lawsuit, since the State had not raised those issues in its appellate briefing. (The State did address the merits in the district court.)

Justice Appel also wrote a lengthy dissent (joined by Justice Hecht) in which he  discussed the importance of education and concluded that education is a fundamental right under the Iowa Constitution. He would subject any “deprivations of a basic or adequate education” to “heightened judicial review,” and analyze “other material differences in education” under some form of the rational basis test.  The plaintiffs, in his view, alleged sufficient facts to withstand a motion to dismiss under either standard.

Chief Justice Cady and Justice Waterman also wrote separate concurring opinions, although they also joined Justice Mansfield’s opinion in full.  They responded directly to the dissenting opinions and emphasized additional reasons for dismissing the plaintiffs’ claims.  (More on the concurring and dissenting opinions in the posts to come.)

That’s the overview.  Next up: constitutional interpretation and the role of the judiciary.


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