Case: Cruz-Guzman v. Minnesota

27-CV-15-19117 | Minnesota state trial court

Filed Date: Nov. 5, 2015

Case Ongoing

Clearinghouse coding complete

Case Summary

On November 5, 2015, seven families and a non-profit organization (One Family One Community) filed this class-action suit on behalf of students enrolled or to be enrolled in the Minneapolis and Saint Paul Public Schools against the State of Minnesota in the Hennepin County District Court. The plaintiffs, represented by private attorneys, alleged that the segregation in the Saint Paul and Minneapolis school districts had produced a "separate and unequal" educational environment in violation of t…

On November 5, 2015, seven families and a non-profit organization (One Family One Community) filed this class-action suit on behalf of students enrolled or to be enrolled in the Minneapolis and Saint Paul Public Schools against the State of Minnesota in the Hennepin County District Court. The plaintiffs, represented by private attorneys, alleged that the segregation in the Saint Paul and Minneapolis school districts had produced a "separate and unequal" educational environment in violation of the Minnesota Constitution. Under Article XII of the Minnesota Constitution, adequate education is a fundamental right. However, the plaintiffs alleged, students were segregated based on race or socioeconomic status, such that schools mainly enrolled by students of color or students living in poverty disproportionately lacked in opportunities compared to neighboring and surrounding affluent suburban school districts. According to the plaintiffs, the defendants (including the Minnesota House of Representatives, the Department of Education, the Commissioner of Education, collectively referred to as the state) failed to address such patterns of segregation. Specifically, the plaintiffs alleged that the state made boundary decisions that foreseeably exacerbated the segregation and approved the formation of charter schools, which were exempt from the state’s desegregation rules and requirements. Moreover, the plaintiffs alleged that the state had used state and federal funds delegated for integration purposes for other uses unrelated to desegregation and the education of socioeconomically deprived children. The plaintiffs argued that public school education was inadequate per se because of its segregation but also substandard by a reasonable and widely accepted measure. Therefore, the plaintiffs alleged violations of the Equal Protection and Due Process Clauses by Minnesota, as the state enabled school segregation and violated plaintiffs' fundamental right to adequate education under the Education Clause. Plaintiffs also brought the suit pursuant to the Minnesota Human Rights Act section 393A.01, alleging unlawful discrimination based on race and status.

The complaint sought declaratory and injunctive relief—that the state be permanently enjoined from "violation of law" and provide the students with "an adequate desegregated education." However, no direct remedies from any specific school were pursued. The plaintiffs also sought attorneys' fees. The case was assigned to Judge Susan Robiner. After the case was filed, three charter schools and several parents intervened as defendants.

The defendants moved to dismiss the complaint. They argued there was a lack of subject matter jurisdiction as education was the responsibility of the legislature, entitled to a legislative immunity under the Speech or Debate Clause of the Minnesota Constitution. The defendants also argued that the plaintiffs failed to join all interested persons, such as school districts and charter schools.

The trial court concluded that there was subject-matter jurisdiction. The court considered a previous similar case, Skeen v. State, where the court determined that Minnesota's Education Clause created a fundamental right to education, therefore, any state action violating that right is subject to judicial scrutiny and immunity claims do not apply. The court also held that school districts and charter schools, while not made parties, were not indispensable to the case and therefore need not to be joined. On July 8, 2016, the court dismissed the plaintiffs' claims brought under the Minnesota Human Rights Act but otherwise denied the defendants' motion to dismiss.

In response, the defendants filed an interlocutory appeal and petitioned the Minnesota Court of Appeals for a discretionary review of the district court's refusal to dismiss the plaintiff's claims on the merits. The appellate court denied the petition on September 13, 2016, because nothing precluded the defendants from continuing to litigate the case and appeal a final judgment. 2016 Minn. App. LEXIS 109. On March 13, 2017, the appellate court held that the plaintiffs' claims presented a nonjusticiable political question against the separation-of-powers principle. The appellate court stated that full redress to the plaintiffs' claims involved establishing a "qualitative educational standard," which was to be determined by the legislature as opposed to the judiciary. Correspondingly, the appellate court reversed the trial court order denying the state’s motion to dismiss the case. Because the ruling on justiciability was dispositive, government immunity and joinder issues were not considered. 892 N.W.2d 533.

The plaintiffs petitioned for further review in the Minnesota Supreme Court. The defendants requested conditional cross-review, to address the legislative immunity and non-joinder of necessary parties. On July 25, 2018, the Supreme Court reversed. It held that the separation-of-powers principles did not prevent the judiciary from ruling on whether the legislature had violated the Education and Equal Protection or Due Process Clauses. The court held that while the legislature played a critical role in education, it was the judiciary's responsibility to determine whether the legislature had fulfilled its constitutional mandate. Therefore, it was determined that the segregation claims were justiciable; the courts were an appropriate domain to determine whether the legislature had violated its constitutional duty under the Education Clause. The Supreme Court upheld the trial court's conclusion that school districts and charter schools were not necessary parties because plaintiffs were seeking remedies form the state, not from individual schools. In terms of government immunity, the Supreme Court held that the Speech or Debate Clause do not extend to claims where the legislature had violated the Education Clause or the Equal Protection or Due Process Clauses. 916 N.W.2d 1.

The case was sent back to the trial court. At some point (it is not obvious from the trial docket when), the trial court certified the plaintiff class as: "all children who are enrolled during the pendency of this action in a school in the Minneapolis Public Schools, Special School District #1, or the St. Paul Public Schools, Independent School District #625, that is racially or socio-economically imbalanced as defined herein: a school with less than 20% or more than 60% minority students or students eligible for free-or-reduced price meals."

In 2019, the parties voluntarily entered into mediation, with the consent of the court. The charter school defendant-intervenors moved for summary judgment in order to be exempt from any ruling or remedy that might result. The trial court denied the motion, noting that two of the three charter schools were very segregated. Mediation commenced in March 2019.

On April 9, 2021, the Minnesota legislature introduced a bill, H.F. 2471. The bill incorporated terms agreed to by the parties during mediation and contained five main components:

  1. A model of identifying students based on multiple economic and social measures,
  2. A requirement to participate in a culturally responsive teacher, inclusion, and integration program for certain categories of districts, traditional public schools, and charter schools,
  3. A voluntary metro-wide integration program,
  4. A diverse magnet school program, and
  5. A statewide information system to facilitate school-by-school comparisons.
The bill also set forth $125 million in 2022-23 and $127 million in 2024-25 for implementing these programs.

On July 27, 2021, the plaintiffs moved for partial summary judgment, requesting the court to declare that the defendants violated the Education Clause, order the defendants to cease their violations, and order the defendants to remedy such violations. They amended the motion on August 11 with a minor change regarding to whom the last item applied.

The court scheduled a trial scheduled for October 31, 2022 in the event that H.F. 2471 failed to pass.

Summary Authors

Averyn Lee (6/9/2019)

Lauren Yu (9/13/2021)

People


Judge(s)

Cleary, Edward J. (Minnesota)

Connolly, Francis J (Minnesota)

Hudson, Natalie E. (Minnesota)

Larkin, Michelle A. (Minnesota)

Attorney for Plaintiff

Almonor, Jeanne-Marie (Minnesota)

Attorney for Defendant
Judge(s)

Cleary, Edward J. (Minnesota)

Connolly, Francis J (Minnesota)

Hudson, Natalie E. (Minnesota)

Larkin, Michelle A. (Minnesota)

Reyes, Peter M. Jr. (Minnesota)

Robiner, Susan (Minnesota)

show all people

Documents in the Clearinghouse

Document

27-CV-15-19117

Docket

Sept. 7, 2021

Sept. 7, 2021

Docket

Class Action Complaint

Cruz-Guzman v. State of Minnesota

Nov. 5, 2015

Nov. 5, 2015

Complaint

A16-1267

A16-1297

Opinion

Cruz-Guzman v. State

Minnesota state appellate court

Sept. 13, 2016

Sept. 13, 2016

Order/Opinion

2016 Minn.App.LEXIS 2016

27-CV-15-19117

A16-1265

Opinion

Cruz-Guzman v. State

Minnesota state appellate court

March 13, 2017

March 13, 2017

Order/Opinion

892 N.W.2d 892

A16-1265

Opinion

Cruz-Guzman v. State of Minnesota

Minnesota state supreme court

July 25, 2018

July 25, 2018

Order/Opinion

916 N.W.2d 916

Resources

Docket

Last updated Aug. 30, 2023, 2:45 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Minnesota

Case Type(s):

School Desegregation

Key Dates

Filing Date: Nov. 5, 2015

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

All children enrolled in a school in the Minneapolis Public Schools or the St. Paul Public Schools that was racially or socioeconomically imbalanced (less than 20% or more than 60% minority students or students eligible for free-or-reduced price meals).

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

State of Minnesota, State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

State law

Constitutional Clause(s):

Due Process

Equal Protection

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: None Yet / None

Nature of Relief:

None yet

Source of Relief:

None yet

Issues

General:

Education

Racial segregation

School/University policies

Discrimination-basis:

Race discrimination

Race:

Race, unspecified