Articles Posted in Kansas Supreme Court

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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

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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

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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