Calculation of “total state spending to all units of Local Government” under § 30 of the Headlee Amendment; Proposal A payments to school districts & Headlee Amendment § 29 state spending to fund state-mandated local services & activities; Whether Public School Academies (PSAs) (commonly referred to as charter schools) are “school districts” as the term is used in the Headlee Amendment; Whether PSAs are political subdivisions of the state for purposes of the Headlee Amendment; Mandamus
The court held that Proposal A payments to school districts and § 29 state spending to fund state-mandated local services and activities are both properly counted in the calculation of “total state spending to all units of Local Government” under § 30 of the Headlee Amendment. Thus, it affirmed Part III(B) and reversed Part III(D) of the Court of Appeals opinion. Also, it held that the Court of Appeals erred in ruling that PSAs are “school districts” as the term is used in the Headlee Amendment and reversed that determination reached in Part III(C) of the opinion. It further held that “PSAs themselves are not political subdivisions of the state for purposes of the” Amendment. But it remanded “to the Court of Appeals to consider whether PSA funding should be counted as spending paid to a unit of ‘Local Government’ if the authorizing body of the PSA is a school district, intermediate school district, or community college.” Finally, it vacated Part III(E) of the opinion without prejudice and remanded for the Court of Appeals to “clarify its grant of mandamus relief or take other action not inconsistent with this opinion.” At issue was a dispute over what monies should be included in calculating “total state spending paid to all units of Local Government” under § 30. Plaintiffs argued that “the state is shortchanging units of local government by improperly inflating that figure.” Specifically, they alleged that Proposal A payments that the state directs to school districts pursuant to § 11 “should not be counted and that neither should state spending for state-mandated local services and activities under” § 29. The court disagreed, holding that both “are properly counted as part of total state spending paid to units of local government for purposes of the Headlee Amendment.” Section 25 “is not an independent source of a substantive right on which plaintiffs can rely, and their arguments find no support in the plain language of § 30.” Justice Viviano, joined by Justice Zahra, concurred in the majority’s decision in all respects except as to Part VI as to funding for PSAs/charter schools. They dissented, believing that “PSAs, as a category, are political subdivisions of the state under” § 33. Thus, they believed that "state spending for PSAs is properly considered ‘spending paid to all units of Local Government’ for purposes of” § 30. In a separate opinion, Justice Clement concurred in full with the court’s resolution of the substantive Headlee Amendment claims. She dissented “only as to the Court’s disposition of the state’s challenge to the writ of mandamus issued by the Court of Appeals (acting as a trial court) in Docket No. 160660.” She found that this aspect of plaintiffs’ case was inadequately pled.
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