## Facts

- Kansas funds K–12 education through a mix of local property taxes and state aid designed to reduce wealth-based disparities among school districts.
- In response to economic conditions beginning around 2009, the Kansas Legislature reduced base state aid per pupil and other formula components.
- The Legislature withheld capital outlay state aid to qualifying districts and reduced supplemental general state aid (an equalization component tied to local option budgets).
- Multiple school districts, students, and guardians sued, alleging (1) constitutionally inadequate overall funding and (2) unconstitutional wealth-based disparities in funding distribution.
- A special three-judge trial court panel held the State violated Article 6 of the Kansas Constitution by underfunding education, failing to consider actual costs, and creating inequities through withholding/reducing specified aid programs.
- The State appealed directly to the Kansas Supreme Court; plaintiffs cross-appealed on certain issues.

## Issues

1. Whether the plaintiffs had standing to challenge the school-finance system under Article 6 of the Kansas Constitution.
2. Whether Article 6 school-finance claims present nonjusticiable political questions.
3. Whether withholding capital outlay state aid and reducing supplemental general state aid created unconstitutional wealth-based disparities in violation of Article 6’s equity component.
4. What legal standard governs Article 6 “adequacy,” and whether the trial court applied the correct standard.

## Decision

- The court held the student and guardian plaintiffs did not meet their burden on standing, but the school districts had standing based on alleged loss of statutorily required aid and resulting injury to their educational operations.
- The court held Article 6 school-finance claims are justiciable and not barred by the political-question doctrine.
- The court adopted an equity rule requiring “reasonably equal access to substantially similar educational opportunity through similar tax effort.”
- The court held the State’s withholding of capital outlay state aid and reduction of supplemental general state aid created unconstitutional wealth-based disparities and affirmed the trial court on equity.
- The court announced a new adequacy standard focused on whether the financing system, in structure and implementation, is reasonably calculated to enable all Kansas public school students to meet or exceed outcome-based educational standards reflected in Kansas law.
- The court reversed the trial court’s adequacy determination for applying the wrong standard and remanded for new adequacy findings and further remedial proceedings consistent with the equity ruling.

## Legal Principles

- Standing is a component of subject-matter jurisdiction and requires a litigant to show a cognizable injury; school districts may have standing to challenge state school-finance actions that reduce legally required aid and impair district operations.
- Courts may adjudicate alleged violations of a constitutional mandate to finance public education; Article 6 school-finance challenges are not categorically barred as political questions.
- Article 6 equity requires school districts to have reasonably equal access to substantially similar educational opportunity through similar tax effort; state actions that remove equalization mechanisms and magnify wealth-based disparities violate this requirement.
- Article 6 adequacy is satisfied when the legislature’s public education financing system—through structure and implementation—is reasonably calculated to have all Kansas public school students meet or exceed legally defined, outcome-based educational standards.
- A trial court’s adequacy analysis must apply the governing constitutional standard; reliance on input measures alone is insufficient without tying financing to the outcome-based benchmarks the standard requires.

## Conclusion

The Kansas Supreme Court held that districts had standing and that Article 6 school-finance claims are justiciable, affirmed that the State’s elimination or reduction of equalizing aid created unconstitutional wealth-based disparities, and remanded for reconsideration of adequacy under an outcome-based standard measuring whether the system is reasonably calculated to enable all students to meet or exceed required educational outcomes.


Gannon v. State, 319 P.3d 1196 (Kan. 2014)