## Facts

- The Richmond Unified School District (RUSD) accumulated severe deficits and announced it would end the 1990–1991 school year about six weeks early because it lacked operating funds.
- Parents of RUSD students filed a class action alleging the planned closure would deny students constitutional rights to equal educational opportunity compared to students statewide who would complete a full term.
- Teachers submitted declarations that early closure would prevent completion of required instruction and grading needed for academic promotion, graduation, and college eligibility.
- The trial court issued a preliminary injunction requiring the State, the State Controller, and the Superintendent of Public Instruction (SPI) to ensure RUSD students received a full school term (or equivalent).
- The court approved an SPI plan using an emergency state loan framework and temporary state control through a state-selected administrator to keep schools open and stabilize district finances.
- The State defendants appealed; the case was transferred to the California Supreme Court, which allowed the injunction to remain in effect while reviewing it.

## Issues

1. Whether the California Constitution imposes an affirmative state duty to prevent a local district’s fiscal failure from depriving its students of basic educational equality.
2. Whether the trial court properly granted a preliminary injunction requiring immediate state intervention to ensure completion of the school term.
3. Whether the injunction exceeded judicial authority by authorizing use of state funds in a manner inconsistent with legislative appropriations.

## Decision

- The court held the State has a constitutional duty to prevent a district’s budget crisis from denying its students basic educational equality.
- The court upheld the trial court’s determination that immediate relief was warranted to prevent imminent, irreparable harm to students from the loss of instruction, grading, and credits within the same school year.
- The court approved state intervention through statutory emergency-loan mechanisms, including temporary displacement of local control by the SPI via an appointed administrator.
- The court modified the injunction to the extent it authorized diverting funds from appropriations clearly designated by the Legislature for other purposes.
- Disposition: affirmed in part and modified in part.

## Legal Principles

- Public education is a fundamental state responsibility under the California Constitution; local school districts function as state agents for operating the statewide school system.
- Equal protection principles in education require at least “basic” educational equality; a district-specific, within-year loss of core instruction and promotion/graduation prerequisites can constitute a constitutionally impermissible disparity.
- The State’s constitutional responsibility is triggered when a local district’s fiscal condition threatens to deprive its students of educational opportunities enjoyed elsewhere in the state.
- Preliminary injunctive relief is proper where school closure is imminent and the resulting educational harms are immediate and not adequately remediable after the fact.
- Separation-of-powers limits constrain remedies: courts may compel the State to meet constitutional obligations and may rely on existing statutory tools, but may not reallocate or redirect legislatively appropriated funds contrary to clear legislative intent.

## Conclusion

The court required the State to act to prevent a local district’s financial collapse from denying students a full, basic educational program, while limiting judicial remedial power to avoid court-ordered funding diversions that conflict with legislative appropriations.


Butt v. State of California, 842 P.2d 1240 (Cal. 1992)