## Facts

- Indiana enacted a statewide textbook-adoption and procurement statute (Act of Mar. 2, 1889) that required township school trustees to report local textbook needs and obtain the selected books through the statutory process.
- Haworth, the school trustee of Monroe Township in Howard County, refused to (1) certify to the county superintendent the number of textbooks needed and (2) procure and furnish the textbooks as required.
- The State, on the relation of Clark and others, sought a writ of mandamus compelling Haworth to perform those statutory duties.
- Haworth resisted, arguing the statute was unconstitutional (as an invasion of local self-government) and disputing the statute’s construction as to trustee obligations.
- The case reached the Indiana Supreme Court on appeal from the Howard County Circuit Court.

## Issues

1. Whether the 1889 statewide textbook statute was unconstitutional as violating principles of local self-government by centralizing textbook selection and imposing duties on local school officials.
2. Whether courts may invalidate or limit the legislature’s chosen structure for administering public education policy when the subject is within legislative authority.
3. Whether the statute imposed clear, mandatory (ministerial) duties on a township school trustee such that mandamus could compel performance.

## Decision

- The court upheld the constitutionality of the 1889 textbook statute.
- The court held that public education, including the regulation and provision of textbooks, is a matter of state concern subject to legislative control rather than a purely local matter insulated by local self-government principles.
- The court held that the legislature may choose centralized or decentralized instrumentalities for administering school policy, and courts cannot control legislative discretion absent a constitutional violation.
- The court construed the statute as imposing mandatory duties on township school trustees to certify textbook needs and to procure and furnish the books under the statutory scheme.
- Because the duties were statutory and non-discretionary, mandamus was an available remedy to compel the trustee’s performance.

## Legal Principles

- Local self-government does not limit the legislature’s authority over subjects that are matters of statewide concern and within legislative competence.
- Public schools and their administration are matters of state governance; the legislature may impose uniform statewide requirements affecting local school officials.
- Courts do not supervise legislative policy choices or administrative design where the legislature acts within constitutional bounds.
- Mandamus lies to compel a public officer to perform a clear, ministerial duty imposed by a valid statute.

## Conclusion

The Indiana Supreme Court sustained a statewide textbook procurement system against a local self-government challenge and confirmed that a township school trustee’s statutorily defined, ministerial duties to report needs and supply textbooks may be enforced by mandamus.


State ex rel. Clark v. Haworth, 122 Ind. 462, 23 N.E. 946 (Ind. 1890)