Minnesota Supreme Court: School Segregation Can Be Unconstitutional Whether or Not the State Caused It

In a crucial decision in Cruz Guzman v. State, a lawsuit challenging segregation in the Minneapolis and St. Paul school districts, the Minnesota Supreme Court ruled on December 13 that there is no need to prove the State caused the segregation in its public schools in order to establish a violation of the Education Clause of the Minnesota Constitution. The Court said plaintiffs can prove a constitutional violation by establishing that de facto segregation is a substantial factor in depriving students of an adequate education.

Parents and their children enrolled in public schools in Minneapolis and St. Paul filed a class action complaint in 2015, contending that school segregation deprived students in these districts of an adequate education, as well as the guarantees of Equal Protection and Due Process, under the Minnesota Constitution. The plaintiffs are represented by a team led by Daniel Shulman of the Minneapolis law firm Shulman & Buske.

The State moved to dismiss the case in 2017, arguing that segregation was a “political question” that could not be decided by the courts. The Minnesota Supreme Court disagreed, ruling it was appropriate for the courts to evaluate whether the Legislature failed to fulfill its constitutional mandate to provide “a general and uniform system of public schools” that is “thorough and efficient.”

In 2021, after the Minnesota Legislature failed to enact a voluntary desegregation plan proposed jointly by the plaintiffs and the State to settle the case, the plaintiffs asked for partial summary judgment on their Education Clause claim.

The district court denied the plaintiffs’ motion, ruling that only de jure, or intentional, segregation could be the basis of an Education Clause claim. The court also ruled that finding an Education Clause violation based on de facto segregation, or segregation in practice, would conflict with federal court precedent. The Minnesota Court of Appeals affirmed the district court’s ruling, and the plaintiffs appealed to the state Supreme Court. During the appeal, the State conceded that the Education Clause does not contain an intent requirement, and the Supreme Court instead focused on causation.

The Supreme Court ruled that because the State has an affirmative obligation to provide a constitutionally adequate education, “the State need not have directly caused the deficiency to be obligated to remedy it under the Education Clause.” The Court decided that the plaintiffs have to establish that de facto segregation is a substantial factor in causing their children to receive an inadequate education and sent the case back down to the trial court for further proceedings consistent with its ruling.

“I applaud the parent plaintiffs in this case for the sacrifice they have made over these last eight years supporting this case for the benefit of all school children in Minnesota,” said the lead plaintiffs’ attorney, Dan Shulman. “I look forward to seeing their fight through to the end. I am confident that we will demonstrate at trial that the deplorable segregation in the Minneapolis and St. Paul school districts deprives students there of adequate educational opportunities.”

“The Minnesota Supreme Court’s recognition that de facto segregation can serve as a basis for a constitutional violation under the Education Clause is monumental,” said Wendy Lecker, Senior Attorney at Education Law Center. “Segregation is simply incompatible with the democratic goals of public education.”

ELC, together with 33 of the nation’s leading education law scholars, submitted an amici curiae, or “friends of the court,” brief in favor of the plaintiffs. The amici were represented pro bono by the law firm Debevoise & Plimpton.

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