Cruz-Guzman v. State

998 N.W.2d 262

Alejandro CRUZ-GUZMAN, as guardian and next friend of his minor children, et al., Appellants,

v.STATE of Minnesota, et al., Respondents,Higher Ground Academy, et al., intervenors, Respondents.

A22-0118

Supreme Court of Minnesota.

Filed: December 13, 2023

Syllabus by the Court

1. The certified question from the district court is reformulated to read as follows: Are racial imbalances in Minneapolis and Saint Paul public schools, as compared to other schools in the same school district, sufficient, standing alone, to establish a violation of the Education Clause of the Minnesota Constitution?

2. Racial imbalances in Minneapolis and Saint Paul public schools, as compared to other schools in the same school district, are not sufficient, standing alone, to establish a violation of the Education Clause of the Minnesota Constitution, Minn. Const. art. XIII, § 1.

3. To prevail on a claim alleging a violation of the Education Clause of the Minnesota Constitution based on racial imbalances in Minneapolis and Saint Paul public schools, appellants do not need to establish that state action caused the racial imbalances; they do need to establish, however, that the racial imbalances are a substantial factor in causing their children to receive an inadequate education.

Court of Appeals

Daniel R. Shulman, Shulman & Buske PLLC, Minneapolis, Minnesota; and Richard C. Landon, Lathrop GPM LLP, Minneapolis, Minnesota; and Mel. C. Orchard, III, The Spence Law Firm, LLC, Jackson, Wyoming; and James Cook, Law Offices of John Burris, Oakland, California, for appellants.

Keith Ellison, Attorney General, Liz Kramer, Solicitor General, Kevin Finnerty, Assistant Attorney General, Saint Paul, Minnesota, for respondents State of Minnesota, et al.

Jack Y. Perry, Brayanna J. Bergstrom, Taft Stettinius & Hollister LLP, Minneapolis, Minnesota; and John Cairns, John Cairns Law, P.A., Minneapolis, Minnesota; and Nekima Levy-Armstrong, Minneapolis, Minnesota, for respondents Higher Ground Academy, et al.

Andrew J. Pieper, John T. Katuska, Brea L. Khwaja, Stoel Rives LLP, Minneapolis, Minnesota; and Teresa Nelson, David P. McKinney, American Civil Liberties Union of Minnesota, Minneapolis, Minnesota, for amici curiae American Civil Liberties Union and American Civil Liberties Union of Minnesota.

Michael V. Ciresi, Roberta B. Walburn, Patrick (Gus) Cochran, Ciresi Conlin LLP, Minneapolis, Minnesota, for amicus curiae Ciresi Walburn Foundation.

Mark R. Bradford, Elizabeth J. Roff, Bradford, Andresen, Norrie & Camarotto, Bloomington, Minnesota, for amici curiae Ed-Allies, Northside Achievement Zone, Project Restore MN, National Parents Union, Coalition of Asian American Leaders, Great MN Schools, Voices for Racial Justice, and Marquita Stephens.

Berglind Halldorsdottir Birkland, Debevoise & Plimpton LLP, New York, New York, for amici curiae Education Law Center and the Constitutional and Education Law Scholars.

Will Stancil, Minneapolis, Minnesota, for amici curiae Minnesota Law Professors.

OPINION

CHUTICH, Justice.

In 2015, appellants Alejandro Cruz-Guzman, et al., ("the parents") brought a class action lawsuit on behalf of children enrolled in Minneapolis and Saint Paul public schools. According to the parents, their "claims all arise from racial and socioeconomic segregation" in the public schools "for which they allege the State is responsible." Among other claims, they assert that racially segregated schools violate their children’s right to an adequate education under the Education Clause of the Minnesota Constitution, Minn. Const. art. XIII, § 1.

Following years of litigation and appeals, including a prior decision by our court holding that the claims are justiciable, Cruz-Guzman v. State (Cruz-Guzman I), 916 N.W.2d 1 (Minn. 2018), as well as unsuccessful efforts to settle the claims, the district court denied the parents’ motion for partial summary judgment on their claim under the Education Clause. But the district court certified a question for immediate appeal, asking whether racial imbalances in Minneapolis and Saint Paul public schools are sufficient, standing alone, to establish a violation of the Education Clause.¹ Answering the certified question, the court of appeals held that an imbalance in the racial composition of a school, "as compared to other schools in the same school district … is not a per se violation of the Education Clause of the Minnesota Constitution, unless the racial imbalance is caused by intentional, de jure segregation." Cruz-Guzman v. State, 980 N.W.2d 816, 820 (Minn. App. 2022). We granted the parents’ petition for further review.

To better address the legal issues presented here, we reformulate the certified question as follows:

Are racial imbalances in Minneapolis and Saint Paul public schools, as compared to other schools in the same school district, sufficient, standing alone, to establish a violation of the Education Clause of the Minnesota Constitution?

We hold that racial imbalances in Minneapolis and Saint Paul public schools, standing alone, are not sufficient to establish a violation of the Education Clause.² Although the parents do not have to establish that state action caused the racial imbalances, we hold that they must show that the racial imbalances are a substantial factor in causing their children to receive an inadequate education. We therefore answer the reformulated certified question in the negative and remand the matter to the district court for further proceedings.

FACTS

In November 2015, appellants Alejandro Cruz-Guzman, et al., ("the parents")³ brought a putative class action lawsuit against the State of Minnesota, Minnesota Department of Education, Minnesota Commissioner of Education, Minnesota House of Representatives, and Minnesota Senate (collectively, "the State"). The parents allege that the State violated their children’s rights under the following constitutional provisions: the Education Clause of the Minnesota Constitution, Article XIII, Section 1; the Equal Protection Clause of the Minnesota Constitution, Article I, Section 2; and the Due Process Clause of the Minnesota Constitution, Article I, Section 7. They sought to represent "a class of children enrolled, or expected to be enrolled during the pendency of this action, in the Minneapolis Public Schools, Special School District No. 1, and the Saint Paul Public Schools, Independent School District 625." The parents did not bring any direct claims against either the Minneapolis Public Schools or the Saint Paul Public Schools. The district court later allowed a group of charter schools ("the Charter Schools")⁴ to intervene.

Allegations and claims. This appeal involves the parents’ claim under only the Education Clause of the Minnesota Constitution. The Education Clause provides that the Legislature has a duty "to establish a general and uniform system of public schools" and "make such provisions by taxation or otherwise as will secure a thorough and efficient system of public schools throughout the state." Minn. Const. art. XIII, § 1. Specifically, the parents contend that the existence of racially imbalanced public schools automatically means the Legislature has violated its duty to provide an adequate education to their children.

The complaint alleges a "high degree of segregation based on race" in Minneapolis and Saint Paul public schools. And the parents argue that there is substantial evidence of worsening segregation. For example, they produced evidence showing that for the 2020-21 school year, Minneapolis Public Schools had 23 schools with more than 80 percent students of color, but 12 schools with fewer than 40 percent students of color. For the same school year, Saint Paul Public Schools had 36 schools with at least 80 percent students of color, of which 28 had at least 90 percent students of color, but 5 schools with at least 53 percent white students.

The complaint also alleges that these racially imbalanced schools have significantly worse outcomes across various academic measures compared to neighboring schools and school districts, which the parents describe as a "large and intractable achievement gap" between white students and students of color. The complaint further alleges other harms created by racially imbalanced schools, including the disproportionate likelihood that students will be placed in special education programs, the reduced likelihood of graduation, and decreased opportunities for interactions with students of other races, leading to reduced "intergroup competency as an adult." Based on these allegations, the parents claim that students attending racially imbalanced schools are not receiving an adequate education.

Finally, as highlighted by the district court’s order denying the parents’ motion for partial summary judgment, the complaint identifies the following State policies and practices that the parents allege con- tribute to the racial imbalances and inadequate educational outcomes:

• a 1999 Minnesota Department of Education desegregation rule that replaced an earlier 1978 desegregation rule;

• policies favoring neighborhood schools;

• charter school exemption from the desegregation rules;

• school boundary lines;

• suburban attendance boundaries;

• open enrollment;

• discipline and suspension policies;

• disparate funding of schools;

• formation of charter schools; and

• misuse of state and federal funds intended to support desegregation.

(Formatting and capitalization altered.)

In sum, the parents claim that the racial imbalances in Minneapolis and Saint Paul public schools prove that the Legislature has failed "to establish a general and uniform system of public schools" and "secure a thorough and efficient system of public schools" as mandated by the Minnesota Constitution. Minn. Const. art. XIII, § 1. Although the parents claim they have evidence of intent and causation, they ask us to hold that racially imbalanced schools are "sufficient to violate the Education Clause,"...