## Facts

- Illinois distributed certain state education funds to school districts as per-capita student tuition, calculated by multiplying a fixed amount per student by the district’s average daily attendance.
- Comprehensive Community Solutions, Inc. (CCS), a nonprofit serving at-risk youth, submitted a charter-school proposal to Rockford School District No. 205 in June 2001.
- CCS proposed operating a charter school for approximately 75–150 at-risk and out-of-school youth over a five-year term, combining academics with vocational training.
- The charter school would be funded primarily through a reallocation of some of the district’s per-capita student tuition revenue from district operations to the charter school.
- At the time CCS applied, Rockford School District No. 205 was in severe financial distress, raising concerns about its ability to continue operating and to absorb additional revenue reductions.
- The local board denied CCS’s proposal, citing the district’s financial condition and the proposal’s projected negative effect on the district’s budget.
- CCS appealed under the Illinois Charter Schools Law to the Illinois State Board of Education (ISBE). An ISBE panel recommended approval, but the State Board upheld the district’s denial by a 4–4 tie vote.
- CCS sought administrative review in circuit court; the circuit court confirmed ISBE’s decision. The appellate court affirmed. CCS then appealed to the Supreme Court of Illinois.

## Issues

1. Whether the Charter Schools Law requirement that a proposal be “economically sound for both the charter school and the school district” permits ISBE to consider the host district’s financial distress and the proposal’s fiscal impact on the district.
2. Whether ISBE’s decision upholding the district’s denial on economic-soundness grounds was clearly erroneous under the standard governing judicial review of mixed questions of law and fact.

## Decision

- The Supreme Court of Illinois held that the statutory economic-soundness requirement allows consideration of the charter proposal’s financial impact on the host school district, including a district’s existing fiscal distress.
- The court held that ISBE’s determination that CCS’s proposal was not economically sound for Rockford School District No. 205 was not clearly erroneous.
- The court affirmed the appellate court judgment, leaving in place the circuit court’s confirmation of ISBE’s decision and the denial of CCS’s charter application.

## Legal Principles

- When statutory text is clear, courts apply its plain meaning; a general statement of legislative aims and a liberal-construction clause do not override an express requirement.
- Under 105 ILCS 5/27A-7(a)(9), a charter proposal must show economic soundness for two entities—the charter school and the host school district—so decisionmakers may evaluate the proposal’s effect on the district’s finances.
- Agency application of a statutory standard to a specific factual record may present a mixed question of law and fact; on administrative review, courts do not substitute their judgment and will overturn only if the agency decision is clearly erroneous.
- In evaluating economic soundness for the district, ISBE may consider evidence that a proposed charter would worsen an already serious deficit and threaten the district’s financial stability.

## Conclusion

*Comprehensive Community Solutions* confirms that Illinois’ Charter Schools Law requires more than showing a charter school can operate financially on its own; the proposal must also be economically sound for the host district. Because the statute expressly requires soundness “for both” the charter and the district, ISBE could weigh Rockford’s grave financial condition and the proposal’s projected budget impact, and the Supreme Court upheld ISBE’s denial under deferential clearly-erroneous review.


Comprehensive Community Solutions v. Rockford School District No. 205, 837 N.E.2d 1 (2005)