8th Circuit Backs School District Consolidation

     (CN) – The 8th Circuit dismissed a challenge to an Arkansas law requiring small school districts to consolidate or be annexed by another district. Judge Gruender said the law makes school districts more cost-effective and efficient.

     A group of taxpayers and parents banded together in 2004 to challenge the state Board of Education’s decision to consolidate Lake View School District with the Barton-Lexa School District.
     The consolidation was mandated by Act 60, which requires school districts with fewer than 350 students to be consolidated or annexed by another district.
     Calling themselves the Friends of Lake View, the opponents of consolidation sued the state, its governor, the commissioner of the state’s Department of Education and the Arkansas Board of Education.
     The outcome of the lawsuit was affected by a 2005 Arkansas Supreme Court decision that the state’s system of public-school financing was “in constitutional compliance,” after a series of legal challenges.
     Based on this ruling, the district court dismissed the Act 60 challenge. However, the court briefly reopened the case in 2007 to determine if it had jurisdiction.
     But the federal judge again rejected the suit, adopting another judge’s “well-reasoned order” in a different case, Friends of Eudora School District v. Beebe.
     Friends of Lake View appealed, arguing that Friends of Eudora wasn’t similar enough to use as a stand-in ruling.
     The appellate panel in St. Louis agreed that some of the findings in Friends of Eudora were “plainly inapplicable,” but nevertheless upheld the district court’s dismissal on other grounds.
     The state “has a legitimate governmental interest in consolidating school districts to achieve economies of scale and other efficiencies,” Judge Gruender wrote, “and the classification drawn between school districts based on their average daily membership is rationally related to advancing that interest.”

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