ST. PAUL, Minn. (Legal Newsline) - Parents who sued the State of Minnesota over racially imbalanced schools in Minneapolis and St. Paul must show the racial differences caused educational shortfalls in order to prove a violation of the state constitution, the Minnesota Supreme Court ruled.
In an opinion issued after the case’s second trip to the Supreme Court, the majority ruled the mere fact schools have racial imbalances isn’t enough to prove they violate the Education Clause of the Minnesota Constitution, which requires “a thorough and efficient system of public schools throughout the state.”
Parents must also prove the imbalances were a “substantial factor” that caused students in those schools to have lower test scores and higher rates of disciplinary actions, the majority said.
The decision keeps alive a lawsuit filed in 2015 by parents who want the judiciary branch to force legislators to enact policy changes to eliminate what they call segregation, but which the Supreme Court described as “de facto, unintentional racial imbalances.” Chief Justice Natalie Hudson dissented, saying “segregation—regardless of its origins—frustrates an essential goal of an adequate education.”
Parents in Minneapolis and St. Paul filed the case, titled Cruz-Guzman v. Minnesota, seeking to include all students at schools with sharp racial imbalances. In 2019, the Minneapolis district had 23 schools with more than 80% students of color and 12 with less than 40%, while St. Paul had 28 schools with 90% students of color and 5 schools that were at least 53% white. The plaintiffs said the racial disparities created a “large and intractable achievement gap.”
To illustrate the supposed harms of segregation, the plaintiffs cited statistics showing 25% of Black students, 30% of Latino and 24% of Native American students were proficient in reading in 2019, compared with 78% of white students and 60% statewide. The state argued the plaintiffs failed to show racial imbalances caused the differences and any remedy would force courts to engage in educational policymaking.
They were joined by charter schools that fear court-ordered desegregation would hurt their ability to serve minority neighborhoods.
The trial court denied both the state's and the parents’ motions for summary judgment, but an appeals court in 2017 ruled the case presented a nonjusticiable political question, which the Minnesota Supreme Court reversed in 2018. In that decision, the high court said the judiciary has the power to decide whether legislators had violated the constitution with its educational policies.
The trial court then certified a class of all students in “racially or socioeconomically imbalanced” schools with less than 20% or more than 60% minority students, or students eligible for reduced-priced meals.
The parents and the state attempted to mediate the dispute, coming up with a bill in 2021 that legislators rejected. The parents then sought partial summary judgment, citing the Supreme Court’s statement in a footnote: “It is self-evident that a segregated system of public schools is not ‘general,’ ‘uniform,’ ‘thorough,’ or ‘efficient.’ ” They argued that meant racial imbalance was a per se constitutional violation, regardless of whether anyone intended it.
The Supreme Court rejected that argument in its Dec. 13 decision.
“We did not -- in a single sentence in a footnote of an opinion addressing justiciability -- designate unintentional racial imbalances in public schools as a per se violation of the Legislature’s duty under the Education Clause,” the court said.
Parents argued they didn’t need to prove intent or causation. Intent isn’t necessary, the Supreme Court said, but causation is.
“We reject the parents’ argument that the district court may order the Legislature to remedy the racial imbalances in the public schools without any showing that the racial imbalances are causally related to the constitutionally inadequate education their children allegedly receive,” the court said.
As for remedies, the majority said it’s too early to talk about them. It cautioned that “specific determinations of educational policy are matters for the Legislature.”
In her dissent, Chief Justice Hudson wrote it wasn’t necessary for parents to prove anything more than that schools are segregated by race.
“Although segregation in public schools is no longer mandated by ordinances and statutes, a confluence of public and private forces have kept the ugly heritage of segregation alive,” she said.