## Facts

- Public-school advocacy groups, students, and parents sued Florida education officials seeking declaratory and injunctive relief under article IX, section 1(a) of the Florida Constitution.
- Plaintiffs alleged Florida failed its “paramount duty” to make adequate provision for a “uniform, efficient, safe, secure, and high quality system of free public schools.”
- Plaintiffs asserted widespread underperformance, with disproportionate impacts on students of color, students with disabilities, English-language learners, and students in poverty.
- Plaintiffs challenged the combined effects of funding, accountability measures, and school-choice mechanisms as producing a fragmented and inequitable system inconsistent with constitutional requirements.
- Plaintiffs did not request a court-ordered funding amount; they sought a declaration of unconstitutionality and an order requiring the State to develop and implement a remedial plan and studies to define necessary resources and standards.
- After extensive discovery and a four-week trial, the circuit court rejected the claims, reasoning that the relief sought exceeded judicial authority.
- The First District Court of Appeal affirmed on the ground that the claims raised nonjusticiable political questions.
- The Florida Supreme Court accepted review and approved the result reached below.

## Issues

1. Whether a system-wide challenge alleging inadequate provision for a “uniform, efficient, safe, secure, and high quality” public-school system under article IX, section 1(a) presents a justiciable controversy.
2. Whether plaintiffs supplied judicially discoverable and manageable standards to evaluate and remedy alleged statewide constitutional deficiencies without intruding on legislative and executive functions.

## Decision

- The Florida Supreme Court approved the result reached by the First District and affirmed the rejection of plaintiffs’ claims.
- A plurality concluded the system-wide adequacy challenge was nonjusticiable because plaintiffs failed to provide manageable standards permitting judicial resolution without improper intrusion into the political branches.
- The court relied on prior precedent treating statewide education-adequacy disputes as political questions when the constitutional language does not yield enforceable metrics for court-directed systemic remedies.
- The court emphasized it was not determining whether Florida’s education system was substantively adequate; it resolved only that the requested statewide adequacy determination and structural relief were for the political branches.

## Legal Principles

- A constitutional claim is nonjusticiable when it requires policy determinations not susceptible to resolution by judicially discoverable and manageable standards.
- Under separation-of-powers limits, courts may not assume ongoing supervisory control over statewide education funding and policy choices by directing broad structural remedies.
- Article IX, section 1(a)’s general terms (including “adequate,” “high quality,” “efficient,” and “uniform”) do not, standing alone, supply an objective, court-administerable standard for system-wide adequacy adjudication and remediation.
- When requested relief would require courts to choose among competing education-policy options and allocate resources at a statewide level, the dispute is committed to the legislative and executive branches.

## Conclusion

The Florida Supreme Court left statewide education adequacy disputes to the political branches, holding that plaintiffs’ system-wide constitutional challenge under article IX, section 1(a) lacked manageable judicial standards and would require impermissible judicial involvement in education policymaking and funding.


Citizens for Strong Schools, Inc. v. Fla. State Bd. of Educ., 262 So. 3d 127 (Fla. 2019)