Iberville Parish School Board v. Louisiana State Board

The Louisiana Legislature passed the Senate Concurrent Resolution No. 55 (SCR 55). SCR 55 created the Minimum Foundation Program (MFP). MFP directed the Louisiana Board of Elementary and Secondary Education (BESE) (defendant) to develop and adopt a formula that reflected the minimum cost for a foundational educational program in all public elementary and secondary schools. BESE adopted a formula that considered the number of students in a school district and the students’ special characteristics. Individual charter schools received their allocated funds once a school system received its MFP allocation. Iberville Parish School Board (Iberville) (plaintiff) and the Louisiana Association of Educators (association) (plaintiff) each filed petitions for injunctive and declaratory relief against the BESE and the State of Louisiana (defendant). The cases were consolidated. Iberville and the association also sought preliminary injunctions and permanent injunctions, arguing that SCR 55 unconstitutionally diverted MFP funds from parish and city schools to charter schools. The district court ruled for the BESE and state, finding that charter schools were public schools. The district court ruled that SCR 55 was constitutional and that SCR 55 did not unconstitutionally divert funds allocated by the MFP. The court of appeal reversed, finding that SCR 55 unconstitutionally diverted MFP funds mandated for parish and city schools to charter schools in violation of Article VIII, Section 13(B) of the Louisiana Constitution. The Louisiana Supreme Court granted writs.