## Facts

- Baker County’s area-wide school reorganization committee proposed creating an “administrative school district” that would combine several smaller districts, including areas commonly referred to as Eagle Valley and Pine Valley.
- Residents of Eagle Valley feared that joining a larger administrative district would eventually lead to loss of their local high school and the construction of a single high school located in the more populous Pine Valley.
- At a public hearing held as part of the statutory reorganization process, a document beginning “To Whomsoever It May Concern” was discussed and was signed by the directors and clerks of the districts to be included in the proposed administrative district.
- The document stated: “That no school be changed, moved or consolidated without the approval of the patrons in the attendance area which that school serves.”
- Eagle Valley residents alleged they were told this “agreement” would be incorporated into the formal reorganization plan and that they voted in favor of forming the new administrative district in reliance on that representation.
- The adopted reorganization plan did not include the promised attendance-area approval condition.
- About five years after the new administrative district was formed, a majority of voters in the administrative district approved a bond issue for one high school for the entire district, to be built in Pine Valley—effectively consolidating local high schools, including the Eagle Valley high school.
- Plaintiffs, Eagle Valley residents suing in a representative capacity, filed a declaratory judgment action against School District No. 61 (the administrative district), seeking a declaration that the district could not close or move the Eagle Valley high school without the consent of Eagle Valley patrons.
- The trial court denied declaratory relief and entered judgment for the school district. Plaintiffs appealed to the Oregon Supreme Court.

## Issues

1. Whether a letter or informal “agreement” signed by directors and clerks of the component districts—along with voters’ reliance on representations that it would be included in the reorganization plan—can legally restrict the reorganized administrative district’s statutory authority to consolidate or relocate schools.
2. Whether, under Oregon’s legislative scheme for public education and school district bonding, a district-wide majority vote approving bonds for a consolidated high school can be made subject to separate approval by patrons in a particular attendance area.

## Decision

- The Oregon Supreme Court affirmed the judgment for the school district.
- The court held that the administrative district’s powers, as granted by the legislature under the statewide framework for public education and school reorganization, could not be limited by the “To Whomsoever It May Concern” document or by residents’ reliance on statements that the document would be included in the reorganization plan.
- The district was not required to obtain separate Eagle Valley patron approval before proceeding with consolidation and the bond-funded high school plan approved by a majority of district voters.

## Legal Principles

- Under Article VIII, section 3 of the Oregon Constitution, responsibility for public education is assigned to the legislature; the organization and powers of school districts are set by statute within that constitutional assignment.
- When the legislature provides that school district bonds and related district actions are authorized by a majority vote of electors of the district, that statutory voting rule governs unless the statute itself creates a different approval requirement.
- Officials of component districts (such as directors and clerks) lack authority to impose conditions that change or limit the statutory powers of a later-created administrative district unless those conditions are adopted through the legally required procedures and are authorized by statute.
- A condition that was not incorporated into the operative reorganization plan cannot be enforced through declaratory relief as if it were part of the district’s governing authority.
- Voter reliance on inaccurate advice or informal assurances cannot be used to prevent a public entity from exercising powers granted by statute within a statewide legislative framework.

## Conclusion

The Oregon Supreme Court ruled that School District No. 61 could proceed with a district-wide, voter-approved bond plan to build a consolidated high school in Pine Valley, even though Eagle Valley residents claimed they voted for reorganization based on a signed letter promising attendance-area control over closures, because that condition was never adopted into the reorganization plan and could not lawfully limit the district’s statutory authority.


Grant v. School District No. 61, Baker County, 415 P.2d 165 (1966)