Justia Education Law Opinion Summaries

In a dispute between Timothy Towne and the Unified School District No. 259, the Supreme Court of the State of Kansas reversed the lower courts' rulings, finding that self-insured school districts are not exempt from regulation under the Kansas Insurance Code. Towne, an employee of the school district, was injured in a car accident and received benefits from the school district's self-funded medical benefit plan. After Towne recovered funds from a third party, the school district required him to reimburse the plan. Towne claimed that the plan's subrogation clause, which allowed for this reimbursement, was unenforceable under Kansas regulations. The district court and Court of Appeals held that the school district's plan was exempt from the Kansas Insurance Code, thereby making the subrogation clause enforceable. However, the Supreme Court reversed, holding that the medical benefit plan offered by the school district is a "health benefit plan" and the school district is a "health insurer" under Kansas law, making the school district subject to the anti-subrogation regulation. The case was remanded for further proceedings. View "Towne v. U.S.D. 259" on Justia Law

The Supreme Court reversed the portion of the district court's judgment declaring 2021 Senate Bill 40 invalid and unenforceable based on certain infirmities the court observed, holding that the district court erred by ignoring the constitutional avoidance doctrine and failing to abide by it.This case arose from a dispute regarding public school policies mandating face masks during the COVID-19 pandemic. After the Legislature passed S.B. 40 imposing substantive limits on COVID-19 mitigation measures adopted by other governmental entities Plaintiffs sued the Shawnee Mission School District challenging the district's mask policy. Plaintiffs asserted S.B. 40 as the only legal authority for their lawsuit. The district court dismissed the claims as moot and then ruled that S.B. 40 was unenforceable because it violated both due process and separation of powers. The Supreme Court reversed, holding that the district court erred in its analytical diversion into S.B. 40's constitutionality. View "Butler v. Shawnee Mission School District Board of Education" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and criminal discharge of a firearm, holding that Defendant's claims of trial error and challenge to his sentence were unavailing.Specifically, the Supreme Court held (1) the district court did not err in failing to give Defendant's requested jury instruction on unintentional but reckless second-degree murder as a lesser included offense of first-degree premeditated murder; (2) the district court did not err by allowing the State to introduce two out-of-court statements; (3) the district court did not err in allowing into evidence eight autopsy photos, a video, and two photos investigators took of Defendant at the time of questioning; and (4) the district court did not abuse its discretion in denying Defendant's motion for a departure sentence. View "State v. Randle" on Justia Law

The Supreme Court held that through Senate Bill 16's (S.B. 16) additional funding of the State's "Montoy safe harbor plan," the State substantially complied with this Court's mandate from Gannon v. State, 420 P.3d 477 (Kan. 2018) (Gannon VI).In Gannon VI, the Supreme Court held that the State had resolved nearly all of the issues in this school finance appeal but that the State had not met Kan. Const. Art. 6, 6(b)'s adequacy requirement. The Supreme Court retained jurisdiction and stayed the issuance of its mandate in order to give the State ample opportunity to make the necessary financial adjustments and reach constitutional compliance. The State subsequently passed S.B. 16, which the Governor signed into law on April 6, 2019. The Supreme Court held that the State substantially complied with the Court's Gannon VI mandate through S.B. 16's financial adjustments to the safe harbor plan. The Court retained jurisdiction to ensure continued implementation of the scheduled funding. View "Gannon v. State" on Justia Law

At issue was whether the State’s remedial legislation, the Kansas School Equity and Enhancement Act (KSEEA), enacted by 2017 Senate Bill 19, met the adequacy requirement of Kan. Const. art. VI, 6(b).In Gannon v. State, 402 P.3d 513 (Kan. 2017) (Gannon V), the Supreme Court held that the State had not met its burden of showing that KSEEA met the adequacy and equity requirements of Article 6. The Court stayed its mandate until June 30, 2018 to give the State ample time to satisfactorily demonstrate that its additional remedial legislation brought the K-12 public education financing system into constitutional compliance. Although the State has still not met the adequacy requirement in Article 6, the Court held that the State has corrected the Gannon V constitutional infrmities and created no others. The Court retained jurisdiction and stayed the issuance of today’s mandate until June 30, 2019, or until further order of the court. Therefore, KSEEA will remain in temporary effect. View "Gannon v. State" on Justia Law

The State did not meet its burden of showing that Senate Bill 19 meets the adequacy and equity requirements set forth in Kan. Const. art. VI, 6(b). S.B. 19 was remedial legislation passed by the legislature in an attempt to bring the State’s education financing system into compliance with Article 6. In one of the four previous decisions by this court in this case, the Supreme Court issued a mandate for the State to create a school funding system that complies with Article 6 of the Kansas Constitution. The Supreme Court held that although S.B. 19 makes positive strides, the State’s public education financing system passes neither the test for adequacy nor the test for equity. As a remedy, the Supreme Court stayed the issuance of its mandate until June 30, 2018, at which time the State will have to satisfactorily demonstrate that its proposed remedy brings the State’s education financing system into compliance with Article 6 regarding adequacy and equity. View "Gannon v. State" on Justia Law

In 2010, Plaintiffs filed an action claiming that the State violated Kan. Const. art. VI, 6(b) by inequitably and inadequately funding K-12 public education. A three-judge panel determined that, through the School District Finance and Quality Performance Act (SDFQPA), the State had inequitably and inadequately funded education in violation of Article 6. On appeal, the Supreme Court affirmed the panel on equity but determined that the panel did not apply the correct standard in concluding that the State violated the adequacy component. On remand, the panel declared the financing under the SDFQPA and the subsequently enacted Classroom Learning Assuring Student Success Act (CLASS), which replaced the SDFQPA, to be constitutionally inadequate. The Supreme Court affirmed, holding that the panel correctly found that the financing system is constitutionally inadequate. As a remedy, the Court stayed the issuance of today’s mandate and ordered that, by June 30, 2017, the State must demonstrate that any K-12 public education financing system the legislature enacts is capable of meeting the adequacy requirements of Article 6. Otherwise, a lifting of the stay of today’s mandate will mean that the State’s education financing system is constitutionally invalid and therefore void. View "Gannon v. State" on Justia Law

On February 11, 2016, the Kansas Supreme Court affirmed the holding of the three-judge district court panel that found changes made to the State's K-12 funding system through enactment of the Classroom Learning Assuring Student Success Act of 2015 (CLASS) violated the equity component of Article 6, section 6(b) of the Kansas Constitution. Specifically, the Court determined the operation of capital outlay state aid and local option budget (LOB) supplemental general state aid, as formulated under CLASS, still allowed inequitable distribution of funding among school districts that it had held unconstitutional in "Gannon v. State," (319 P.3d 1196 (2014) (Gannon I)). This case required the Supreme Court to determine whether the State met its burden to show that recent legislation brought the State's K-12 public school funding system into compliance with Article 6 of the Kansas Constitution. After review, the Court held that it had not: (1) H.B. 2655 cured the capital outlay inequities affirmed to exist in "Gannon II;" (2) H.B. 2655, which included a hold harmless and extraordinary need provisions, failed to cure the LOB inequities affirmed to exist in Gannon II; and (3) the unconstitutional LOB funding mechanism was not severable from CLASS, thus making CLASS unconstitutional. View "Gannon v. Kansas" on Justia Law

In Gannon I, the Supreme Court confirmed that Article 6 of the Kansas Constitution, which imposes a duty on the legislature to “make suitable provision for finance of the educational interests of the state,” contains both equity and adequacy requirements. On remand, a three-judge district court panel made various rulings. At issue on appeal was the panel’s holding that the State failed to comply with the Supreme Court’s Gannon I directive on equity due to the 2015 legislature amending capital outlay state aid and supplemental general state aid formulas for fiscal year 2015 and repealing the amended aid formulas for fiscal years 2016 and 2017. The Supreme Court affirmed in part and reversed in part, holding (1) the panel unnecessarily ordered State officials to be joined as parties; (2) the panel had the authority to review the law changing the entitlements for fiscal years 2016 and 2017; (3) the panel properly concluded that the State failed to cure the inquiries affirmed to exist in Gannon I; (4) Plaintiffs were not entitled to attorney fees; and (5) the panel’s remedy was premature. View "Gannon v. State" on Justia Law