William Penn School District v. Pennsylvania Department of Education (2017) [School Funding Lawsuit]

Summary:

The Pennsylvania Supreme Court’s majority—Justices Todd, Wecht, Donohue, Dougherty, and Mundy—held that Pennsylvania courts must evaluate claims that the commonwealth’s method of school funding was unconstitutional. Reversing decades of Pennsylvania Supreme Court precedent, the court concluded that the state’s Education Clause was capable of judicial interpretation and remanded for consideration on the merits. Dissenting Chief Justice Saylor and Justice Baer would have held that the Education Clause is a nonjusticiable political question, making the General Assembly responsible for its implementation.

The Verdict:

The majority discarded decades of precedent and held that Pennsylvania courts must wade into the difficult waters of state educational and fiscal policy. Similar rulings by other state supreme courts demonstrate that this puts judges without any relevant expertise in the position of second-guessing legislative policy determinations that inherently involve political trade-offs. Worse, because judicial determinations as to the adequacy of state funding construe state constitutional provisions, their rulings are constitutionalized, making them impossible to change through the normal political process.

Background:

This case began in 2014, when the Public Interest Law Center (PILC) filed a lawsuit in the Commonwealth Court alleging that disparities in state funding and resources made the General Assembly’s method of education funding unconstitutional under both the commonwealth’s Education Clause—which requires a “thorough and efficient public school system”—and the Equal Protection Clause.

The Commonwealth Court dismissed the case as raising nonjusticiable “political questions” in accordance with decades of Pennsylvania Supreme Court precedent. Under that precedent, Pennsylvania courts would not question the legislative scheme for public school financing, as long as the scheme is “reasonably related” to the maintenance and support of a thorough and efficient public school system.

After the Supreme Court determined that the political question doctrine did not bar consideration of PILC’s lawsuit on the merits, the case went back to the Commonwealth Court. In 2023, the Commonwealth Court issued a decision holding that Pennsylvania’s school funding system was unconstitutional and required the remaining branches of government to work through the political process to revise it.