## Facts

- A coalition of Montana public school districts, education associations, parents, and taxpayers sued the State alleging unconstitutional administration and funding of the public school system.
- After a bench trial, the district court found serious deficiencies in the school finance system and concluded the State had not defined the constitutional requirement of “quality” education.
- The district court held the funding system violated the Montana Constitution’s Public Schools Clause (Art. X, § 1(3)) and Indian Education Clause (Art. X, § 1(2)), granted declaratory relief, set an effective date for the ruling, and addressed attorney-fee requests.
- The State appealed, arguing the claims were a nonjusticiable political question and that the system met constitutional requirements.
- The coalition cross-appealed on the effective date, attorney fees, and additional constitutional theories (including equal protection).

## Issues

1. Whether a challenge to the adequacy of the State’s public school funding under Art. X, § 1(3) presents a nonjusticiable political question.
2. Whether the existing school finance system violates Art. X, § 1(3)’s requirement that the legislature provide a “basic system of free quality public elementary and secondary schools.”
3. Whether the State violated the Indian Education Clause, Art. X, § 1(2), regarding preservation of American Indian cultural integrity in educational goals.
4. Whether the court needed to reach equal protection claims after finding violations of the education clauses.
5. Whether the district court’s effective date and attorney-fee rulings were proper.

## Decision

- The Montana Supreme Court held the case was justiciable; review of whether the enacted system complies with the constitution is a judicial function.
- The court affirmed that the school funding system violated Art. X, § 1(3) because it was not structured around a legislative definition of “quality” or a determination of the costs of providing constitutionally required quality education.
- The court affirmed the finding of a violation of the Indian Education Clause, noting the State did not meaningfully challenge the supporting findings on appeal.
- The court declined to decide the equal protection claim after resolving the case under the more specific education clauses.
- The court affirmed the district court’s prospective effective date for the declaratory judgment to allow legislative response.
- The court vacated and remanded the attorney-fee ruling for reconsideration under the private attorney general doctrine as recognized in recent precedent.

## Legal Principles

- Education-adequacy claims under the Montana Constitution’s education provisions are justiciable once the legislature has enacted a school system; courts may assess constitutional compliance.
- Art. X, § 1(3) requires more than distributing funds; the finance system must be designed to implement a “free quality” education, grounded in a legislative definition of “quality” and an analysis of what it costs to provide it.
- Standardized test performance does not, by itself, establish constitutional compliance where the system lacks a constitutionally grounded design and funding basis.
- Art. X, § 1(2) imposes enforceable obligations concerning American Indian cultural heritage and educational commitments; failure to implement those commitments can be unconstitutional.
- Courts may avoid deciding broader constitutional theories (such as equal protection) when narrower, directly applicable constitutional provisions resolve the dispute.
- Attorney fees in public-rights litigation may be available under the private attorney general doctrine, requiring case-specific reconsideration when the doctrine applies.

## Conclusion

The Montana Supreme Court upheld declaratory relief that the State’s school funding system violated the Public Schools and Indian Education Clauses because it was not built on a defined and costed conception of constitutionally required “quality” education, rejected the State’s political-question defense, left equal protection unresolved as unnecessary, maintained a prospective effective date, and remanded attorney fees for reconsideration under the private attorney general doctrine.


Columbia Falls Elementary Sch. Dist. No. 6 v. State, 109 P.3d 257 (Mont. 2005)