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MONTANA

Columbia Falls Elem. Sch. Dist. No. 6 v. State of Montana, 326 Mont. 304, 109 P.3d 257 (Mont. 2005).

The Supreme Court in Columbia Falls Elem. Sch. Dist. 6 v. State invalidated the Montana school finance system, in part, because the state had failed to define a "quality public education" as that term is used in the state constitution, and therefore had "no reference point from which to relate funding to relevant educational needs." The Court deferred to the legislature to define a quality public education, yet at the same time recognized that an adequate education most include state curriculum and learning standards: "Unless funding relates to needs such as academic standards, teacher pay, fixed costs, costs of special education, and performance standards, then the funding is not related to the cornerstones of a quality education." 326 Mont. at 312, 109 P.3d at 262.

 

Helena Elem. Sch. Dist. No. 1 v. State of Montana, 236 Mont. 44, 769 P.2d 684 (Mont. 1989).

Plaintiff school districts sought a declaratory judgment that the state’s system of financing public education violated the education and equal protection provisions of the state constitution.  The Montana Supreme Court ruled that the state’s failure to fund education adequately, which resulted in “excessive reliance on permissive and voted levies,” was a failure to “provide a system of quality public education granting to each student the equality of educational opportunity” guaranteed by the state constitution.  The Court further held that spending disparities among the state's school districts “translate[d] into a denial of equality of educational opportunity” in violation of the constitution.

The Court did not establish a standard for a constitutionally adequate education, but noted that  the Montana School Accreditation Standards established by the State Board of Public Education were “minimum standards upon which quality education must be built,” and thus the standards did not “fully define either the constitutional rights of students or the constitutional responsibilities of the State of Montana for funding its public elementary and secondary schools.” 236 Mont. at 57, 769 P.2d at 692.