In Cahokia Unit School District No. 187 et al. v. Pritzker, an Illinois appellate court upheld the dismissal of a complaint brought on behalf of 22 Illinois school districts claiming that the State of Illinois and the Governor unlawfully failed to provide adequate funding necessary for school districts to provide their respective students with a high-quality education and comply with State educational requirements, and that the disparities in per-pupil expenditures across the school districts of Illinois have no legitimate basis in the law.
The school districts filed a complaint arguing that the State has revised and expanded the educational requirements to which each school district is held accountable, serving to remove local control of education from school districts. The complaint alleged that funding is provided by the State to assist in meeting these requirements, but the funding is inadequate to provide the school districts the resources necessary to comply with the educational requirements and to provide students with a high-quality education. The complaint also alleged that the disparities in per-pupil expenditures across the school districts in Illinois, which ranged as high as $10,000 to $15,000 per student, have no legitimate basis in the law and therefore violate students’ equal protection rights under the Illinois Constitution.
The Illinois Constitution tasks the State with providing an efficient system of high-quality public education and services. The court determined that past rulings by the Illinois Supreme Court precluded the court from making a judgment concerning what constitutes a “high-quality” education and from determining that the school funding system violated students’ equal protection rights. The school districts argued that the ever-expanding education requirements imposed by the State have provided the framework for what constitutes a “high-quality” education, and they were without the funding or local control to meet that standard. The court appeared to agree to some extent with the school districts, but in the end, the court reverted to relying on Illinois Supreme Court precedent.
Ultimately, the court upheld the dismissal of the school districts’ complaint and essentially punted to the Illinois Supreme Court for a decision on the merits. An appeal of the appellate court’s decision may task the Illinois Supreme Court with revisiting whether Illinois school districts are unlawfully underfunded for the education requirements imposed on them by the State.
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