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Case Name Cruz-Guzman v. Minnesota SD-MN-0002
Docket / Court (2015) ( State Court )
State/Territory Minnesota
Case Type(s) School Desegregation
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 ... read more >
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 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 colour or students living in poverty disproportionately lacked in opportunities compared to neighbouring 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 segregations. 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 attorney fees.

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 appellants’ claims brought under the Minnesota Human Rights Act but otherwise denied the respondents’ motion to dismiss.

In response, the state filed an interlocutory appeal. The Appeals 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 appellants’ claims involved establishing a “qualitative educational standard,” which was to be determined by the Legislature as opposed to the judiciary. Correspondingly, the court of appeals reversed the trial court order denying the state’s motion to dismiss the case on March 13, 2017. 892 N.W.2d 533. Because the ruling on justiciability was dispositive, government immunity and joinder issues were not considered

The plaintiffs petitioned for further review in the Minnesota Supreme Court. 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. Supreme Court reversed the decision of the court of appeals in favour of the appellants. 916 N.W.2d 1.

The case was sent back to the Hennepin County district court, where it is ongoing.

Averyn Lee - 06/09/2019


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Equal Protection
Defendant-type
Jurisdiction-wide
Discrimination-basis
Race discrimination
General
Racial segregation
Plaintiff Type
Private Plaintiff
Race
Race, unspecified
Causes of Action State law
Defendant(s) State of Minnesota
Plaintiff Description seven families and one non-profit organization on behalf of students enrolled or to be enrolled in the Minneapolis and Saint Paul Public Schools against the State of Minnesota
Class action status sought Yes
Class action status granted Pending
Filed Pro Se No
Prevailing Party None Yet / None
Public Int. Lawyer No
Nature of Relief None yet
Source of Relief Litigation
Filing Year 2015
Case Ongoing Yes
Additional Resources
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  Justiciability of State Law School Segregation Claims
Date: Jul. 31, 2018
By: Will Stancil; Jim Hilbert (Mitchell Hamline School of Law)
[ Detail ] [ External Link ]

  CRUZ-GUZMAN V. STATE OF MINNESOTA
Date: Jun. 1, 2017
By: ACLU Minnesota
Citation: https://www.aclu-mn.org/en/cases/cruz-guzman-v-state-minnesota
[ Detail ]

  STATEMENT OF THE PLAINTIFFS IN CRUZ-GUZMAN V. STATE OF MINNESOTA EDUCATIONAL ADEQUACY CASE
Date: Nov. 5, 2015
By: Daniel Shulman
[ Detail ] [ External Link ]

Docket(s)
27-CV-15-19117 (State Trial Court)
SD-MN-0002-9000.pdf | Detail
Date: 10/14/2016
Source: Westlaw
General Documents
Class Action Complaint
SD-MN-0002-0001.pdf | External Link | Detail
Date: 11/05/2015
show all people docs
Judges Robiner, Susan Court not on record show/hide docs
SD-MN-0002-9000
Plaintiff's Lawyers Almonor, Jeanne-Marie (Minnesota) show/hide docs
SD-MN-0002-0001
Shulman, David L. (Minnesota) show/hide docs
SD-MN-0002-0001 | SD-MN-0002-9000
Defendant's Lawyers Olson, Karen Diane (Minnesota) show/hide docs
SD-MN-0002-9000

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