New Mexico Judge Rules That State Education Finance System Is Unconstitutional

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New Mexico Judge Rules That State Education Finance System Is Unconstitutional

In a wide-ranging 76-page decision issued late last month, New Mexico District Court Judge Sarah M. Singleton ruled that the state’s education finance system violated the Education Clause, the Equal Protection Clause and the Due Process Clause of the state constitution (Martinez v. State of New Mexico). The judge issued a declaratory judgment that gave the state until April 15, 2019 ,to take “immediate steps to ensure that New Mexico schools have the resources necessary to give at-risk students the opportunity to obtain a uniform and sufficient education that prepares them for college and career.” The Court retained jurisdiction and indicated that injunctive relief would be forthcoming if the legislature did not provide appropriate reforms by the deadline date.

Judge Singleton’s decision reviewed prior decisions of other state courts in adequacy and equity cases and determined that the appropriate standard for reviewing the state’s compliance with constitutional requirements should be whether the preponderance of evidence shows a rational relationship to the constitutional standard of providing all school children an adequate education. The Court also defined “at risk” students to include all students who are economically disadvantaged, English language learners, students with disabilities and Native American students. She found that the vast majority of students in New Mexico are “at risk,” given that 71.6% of students in New Mexico are from low-income families and substantial numbers of students also fit into the other categories.

The Court invoked  the “inputs/outputs” analytical framework utilized by the New York Court of Appeals in CFE v. State of New York, 801 N.E. 2d 326 (2003), holding that among other things, instructional materials, class sizes, technology, and teacher quality were inadequate. The Court’s analysis also included a number of findings and holdings that went beyond previous precedents, including the following:

  1. Pre-school, after-school and summer school programs have been shown to provide proper supports for at risk students;
  2. A  “value-added”  teacher evaluation system that considers student outcomes in assessing teacher competence “penalizes teachers for working in high needs schools [and] contributes to the problem;”
  3. In assessing student achievement outputs, more than nominal growth must be shown
  4. Students needing college remediation are not college ready;
  5. A 10% extra weighting for at risk students in the funding formula is not acceptable;
  6. The state education department is responsible for monitoring spending by school districts to ensure both that they are using these funds as required to provide educational opportunities for at-risk students, and that they are using the funds effectively and efficiently.

The state has announced that it will appeal the decision, but the intention to appeal quickly became an issue in the upcoming gubernatorial campaign. Democratic gubernatorial candidate Michelle Lujan Grisham, asked Susana Martinez, the current governor, not to appeal and said if she’s elected, she would ‘immediately halt any appeal … upon taking office.’ A spokesman for Republican gubernatorial candidate Steve Pearce,  stopped short of saying Pearce would quell the appeal but said, “As the court battle goes forward, Steve Pearce remains committed to taking action as governor to fix New Mexico’s broken education system and addressing the serious problems the judge points out in her decision.”

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