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No. 137424, 137453
| Daniel Adair, et al., |
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Dennis R. Pollard |
Plaintiffs-Appellants, |
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(Appeal from Ct of Appeals) |
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State of Michigan, |
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Timothy J. Haynes |
Defendant-Appellee. |
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------------------------------------------------------ |
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Daniel Adair, et al., |
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Plaintiffs-Appellees, |
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| State of Michigan, |
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Defendant-Appellant. |
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| __________________________________________ |
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Click to view briefs in Adobe format:
137424 - Plaintiffs-Appellants' Brief on Appeal>>
137424 - Plaintiffs-Appellants' Reply Brief>>
137424 - Defendant-Appellee's Brief on Appeal>>
137453 - Plaintiffs-Appellees' Brief on Appeal>>
137453 - Defendant-Appellant's Brief on Appeal>>
137453 - Defendant-Appellants' Reply Brief>>
Background
In 2000, the plaintiffs, a group of school districts, filed an original action against the state of Michigan in the Court of Appeals. They contended that the legislature had violated the Headlee Amendment by failing to fund various new educational activities and services. The Headlee Amendment prohibits the legislature from requiring any new or increased service (beyond that required by existing state law) from a unit of local government, “unless a state appropriation is made and disbursed to pay the unit of local government for any necessary increased costs.” Const 1963, art 9, § 29. Many of the plaintiffs’ claims were dismissed.
This appeal involves the plaintiffs’ remaining Headlee claim. MCL 388.1752 requires local school districts to report certain data in order to obtain funding. Through an executive order issued in 2000, the state consolidated various information gathering functions in a central data repository, the Center for Educational Performance and Information (CEPI). CEPI then created four separate electronic databases, each of which imposes special data gathering and reporting requirements on local school districts. The plaintiffs claimed that, through CEPI, the state improperly shifted its data-keeping function to the local level without providing necessary additional funding.
The Court of Appeals appointed a special master to review the evidence. Analyzing CEPI’s impact on local school districts, the special master concluded that, “[t]hrough the implementation of the databases, the state is requiring the districts to actively participate in collecting, maintaining and reporting data that the state requires for (only) its own purposes.” While the plaintiffs presented little evidence that the school districts had incurred actual additional costs, this was not fatal to their Headlee claim, the special master said, because the plaintiffs did establish that the school districts diverted significant local resources to comply with the new requirements. The state argued that it had complied with Headlee by providing significant discretionary funding to the local districts, which the plaintiffs had used to comply with the CEPI requirements. But the special master rejected that argument, ruling in the plaintiffs’ favor.
In a published opinion, the Court of Appeals adopted the special master’s opinion and findings of fact with a few modifications. The court agreed that, in order to meet their burden of showing a Headlee Amendment violation, the plaintiffs only needed to demonstrate that the state mandated a new level of activity and failed to provide funding for the necessary costs. The Court of Appeals adopted the special master’s findings regarding CEPI and the increased demands that it placed on local districts. The Court of Appeals also rejected the state’s claim that it met its obligation to the plaintiffs by providing discretionary funding. Because the legislature did not appropriate any categorical funding for the CEPI-associated costs, the appeals court concluded that the state had failed to provide the necessary costs associated with these requirements. The Court of Appeals denied the plaintiffs’ request for costs and attorney fees associated with prosecuting their case, reasoning that, under the Headlee Amendment, such costs are properly awarded if “the suit is sustained.” Because the plaintiffs had prevailed on only one of their many claims, the Court of Appeals ruled that this requirement had not been satisfied. Both the plaintiffs and the defendant appeal.
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