MINNESOTA

Constitutional Clause/Language

“The stability of a republican form of government depending mainly upon the intelligence of the people, it is the duty of the legislature to establish a general and uniform system of public schools. The legislature shall make such provisions by taxation or otherwise as will secure a thorough and efficient system of public schools throughout the state.” Minn. Const. art. XIII.

Major Court Decision: Skeen v. State, 505 N.W.2d 299, (Minn.1993).

Result: Financing system upheld

Summary: The Minnesota Supreme Court held that there is a “fundamental right to a basic level of funding,” but that right does not require equality of spending among districts.  Additionally, the court decided that the “through and efficient” standard only requires a rational basis standard of review.

Key Quotes:

“While State Constitution creates fundamental right to ‘general and uniform system of education’ for purposes of equal protection analysis, that right does not extend to funding of education system beyond providing basic funding level to assure that general and uniform system is maintained and, thus, while strict scrutiny analysis should be applied in determining whether legislature has met student's fundamental right to general and uniform system of public schools, lesser standard of rational basis test should apply to determination of whether financing of such system is thorough and efficient.”  Id. at 315.

“Because the state constitution does not require strict economic equality under the equal protection clause, it cannot be said that there is a ‘fundamental right’ to any particular funding scheme, although, as we said above, there is a fundamental right to the basic level of funding needed to achieve a general and uniform education system. Where the state constitution merely requires that the funding of education ‘secure a thorough and efficient system’; the particular means employed to finance state education are left to the legislature's determination. Thus, we believe that challenges to the state's financing of education beyond what is necessary to provide an adequate level of education which meets all state standards must be evaluated, not under strict scrutiny, but rather under the rational basis test, and we will not set aside the legislature's determination unless the funding system employed somehow impinges upon the adequacy with which the state meets the fundamental right to a general and uniform education... Any inequities which exist do not rise to the level of a constitutional violation of the state constitutional provisions which require the state to establish a ‘general and uniform system of public schools’ which will secure a ‘thorough and efficient system of public schools,’ especially when the existing system continues to meet the basic educational needs of all districts.”  Id. at 316.