Federal Way Sch. Dist. No. 210 v. State
The legislatures formulas for funding school’s do not violate our State Constitutional mandate in Article IX, s. 2. Section 2 of Article IX states, “[t]he legislature shall provide for a general and uniform system of public schools.” Uniformity doesn’t mean uniform base salaries for everyone, but rather, “that ‘every child shall have the same advantages and be subject to the same discipline as every other child.’ Sch. Dist. No. 20 v. Bryan, 51 Wash. 498, 502, 99 P. 28 (1909).
Our cases discussing article IX, section 2 make it clear that the provision requires uniformity in the educational program provided, not the minutiae of funding. Such details — unless specifically mandated by the constitution — are the province of the legislative branch. See Const. art. II, § 1 (legislative authority vested in the legislature, subject to powers reserved by the people); Const. art. IX, § 2 (mandating limits on the use of common school fund revenues). Federal Way School District fails to overcome the presumption that the statutory funding formulas are constitutional and fails to prove that the disparities in those formulas have violated article IX, section 2.
Federal Way also made an Article IX s. 1 argument that the State failed to fund all school districts the same. Unfortunately, the clause only requires ample funding, not uniform funding. No case has ever required that ample means uniform formulas for salary.
Finally, and this doesn’t come up often, the court held that the individual parent claims weren’t justiciable. The individual claimants tried to claim they were denied a benefit by the use of a different formula. However, the formula allocates money to the school, not to any individual, thus they had no claim to the moneys. They were unable to show any actual harm, unlike the Seattle Sch. Dist. No. 1 case, in which the levy program was alleged to have caused sufficient harm. The students, in fact, are above average.
