School Funding Case Finally Resolved
On October 21, 2021, the Illinois Supreme Court issued an opinion in Cahokia Unit School District No. 187 v. Pritzker, which was a challenge mounted by several school districts to the constitutionality of Illinois’ school funding system.
The plaintiff school districts sought a judgment declaring that the defendants, Governor J. B. Pritzker and the State of Illinois, have a constitutional obligation to provide them with funding necessary to meet or achieve the learning standards established by the Illinois State Board of Education. The case was originally filed against then-Governor Rauner, and Governor Pritzker was subsequently substituted as the defendant upon becoming governor.
Both the trial court and the appellate court granted the State defendants’ motion to dismiss the complaint, ruled that plaintiffs’ claims were barred by the doctrine of sovereign immunity and that plaintiffs’ complaint also failed to state a valid cause of action. Relying on the Illinois Supreme Court’s decision in Committee for Educational Rights v. Edgar, 174 Ill. 2d 1 (1996), the trial court and the appellate court concluded that decisions on the quality of public education and the appropriation of funds to support legislative enactments are exclusively within the authority and control of the General Assembly.
In arguing the case before the Illinois Supreme Court, plaintiffs acknowledged prior case law on this issue, but they contend that circumstances have changed since Edgar was decided (including both the adoption of the new learning standards and the enactment of evidence based funding). However, the Illinois Supreme Court held that the Governor is not a proper defendant because he has no authority to take the action requested by plaintiffs. The Illinois Supreme Court affirmed the dismissal of the case.