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Edgewood Independent School District v. Kirby

Supreme Court of Texas · 1991 · Constitutional Law

Constitutional LawTexas ConstitutionPublic school financeMandamusEducation fundingefficient system of public free schoolsarticle VII section 1school finance

Facts

This litigation challenged the constitutionality of the Texas public school finance system under article VII, section 1 of the Texas Constitution. After Edgewood I, the Legislature enacted Senate Bill 1, which retained the Foundation School Program's two-tier structure, added biennial studies and policy mechanisms aimed at fiscal neutrality, and attempted to equalize funding for districts educating 95% of students. Senate Bill 1 did not alter district boundaries, left roughly half of education funding dependent on local property taxes, and excluded 132 wealthy districts educating about 170,000 students and holding about 15% of the state's property wealth from the equalization formula. The district court concluded the system remained unconstitutional but vacated the injunction out of deference to the Legislature and concern about disruption to public education.

Issue

Whether Senate Bill 1 changed the school finance system enough to eliminate the constitutional violation identified in Edgewood I, and if not, whether the district court could vacate the Supreme Court's previously affirmed injunction on equitable grounds despite finding no changed conditions.

Rule

Absent changed conditions, a trial court must observe and enforce the Supreme Court of Texas's mandate as rendered; equitable concerns already considered by the Court are not changed conditions permitting a lower court to vacate that mandate. Under article VII, section 1, a public school finance system is not efficient if it fails to provide a direct and close correlation between a district's tax effort and the educational resources available to it; when the system depends heavily on local ad valorem property taxes, efficiency requires that revenue be drawn from all property at a substantially similar rate.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Supreme Court of Franklin previously affirmed an injunction barring further operation of the state's public-school funding statute unless the legislature adopted a constitutional replacement. After a new statute passed, a trial judge in Columbus held the revised statute still unconstitutional but dissolved the injunction because shutting down funding would be too disruptive for students and because the judge wanted to give the legislature another year to work.

If the supreme court applies the majority rule from this case, what is the best result?

Explanation. Absent changed conditions, a trial court must observe and enforce the supreme court's mandate as rendered. Concerns about disruption and deference to the legislature are not changed conditions when those concerns were already present and considered before. If the lower court finds the constitutional violation persists, it may not vacate the higher court's injunction on policy grounds.