## Facts

- A coalition of school districts, school boards, students, and parents challenged Illinois’ statutory public school funding system.
- The system relied heavily on local property taxes, supplemented by state aid and some federal funds.
- Because district property wealth varied widely, the system produced substantial disparities in per-pupil spending and available educational resources among districts.
- Plaintiffs alleged these disparities resulted in unequal educational quality (including differences in programs, facilities, and services).
- Plaintiffs sought a declaratory judgment that the funding scheme violated the Illinois Constitution’s education article, equal protection clause, and prohibition on special legislation.
- The circuit court dismissed the complaint; the appellate court affirmed; the Illinois Supreme Court granted review and addressed the constitutional claims.

## Issues

1. Whether the Illinois Constitution’s education article provides judicially enforceable standards allowing courts to adjudicate claims that the statewide school finance system is not an “efficient” system of “high quality” public education.
2. Whether funding disparities tied to local property wealth violate equal protection under the Illinois Constitution.
3. Whether the funding scheme constitutes unconstitutional special legislation by favoring certain districts based on property wealth.

## Decision

- The Illinois Supreme Court affirmed dismissal of the complaint.
- Education article: held the claim was nonjusticiable because the constitutional language did not supply judicially manageable standards for “efficiency” or “high quality,” and the matter was committed to the legislature.
- Equal protection: held education is not a fundamental right and wealth is not a suspect classification; applying rational-basis review, the funding system was rationally related to legitimate interests, including local control.
- Special legislation: held the scheme did not violate the special legislation prohibition; the classifications inherent in the funding system had a rational basis.

## Legal Principles

- A constitutional provision stating broad educational goals and directing the State to provide an “efficient” system of “high quality” public education does not, without manageable standards, create a judicially enforceable right to a particular level or equality of school funding.
- Under Illinois equal protection doctrine, education is not a fundamental right and wealth-based disparities in school funding are evaluated under rational-basis review.
- Promoting local control and permitting communities to vary educational spending through local taxation can constitute legitimate governmental objectives supporting a school finance scheme under rational-basis review.
- A funding classification that survives rational-basis review generally does not amount to unconstitutional special legislation.

## Conclusion

The Illinois Supreme Court rejected a constitutional attack on Illinois’ reliance on local property taxation for school funding, ruling that the education article claim presented a nonjusticiable political question and that the resulting funding disparities did not violate equal protection or the prohibition on special legislation under rational-basis review.


Comm. for Educ. Rts. v. Edgar, 672 N.E.2d 1178 (Ill. 1996)