Lake View School District No. 25 of Phillips County, Arkansas, Appellants v. Governor Mike Huckabee; Senator…

Summary

The Arkansas Supreme Court affirmed the chancery court's declaration that the post-1994 public school-funding system is unconstitutional under Article 14, § 1, because the State failed its absolute duty to provide a general, suitable, and efficient education, and under Article 2, §§ 2, 3, and 18, because equal educational opportunity—measured by actual expenditures per student rather than equalized revenues—is not afforded and no rational basis justifies the disparities in curriculum, facilities, equipment, and teacher pay. It rejected the State's nonjusticiability and separation-of-powers challenge, declined to decide whether an adequate education is a fundamental right requiring strict scrutiny, held that courts cannot mandate pre-kindergarten programs or specific remedies, and struck down the statute crediting excess debt service millage against Amendment 74's uniform 25-mill rate as void. It affirmed the fee award in principle but modified it to a lodestar-based $3,088,035 (stated as $3,088,050 in the opening paragraph) plus $309,000 in costs, rejecting percentage-of-common-fund and multiplier methods. Justice Hannah concurred to emphasize the General Assembly's exclusive policy role and a duty-focused reading of Article 14; Justice Glaze concurred in part and dissented in part, objecting to the compliance-trial procedure and the reported stay of the mandate; Justice Corbin concurred to condemn Lake View counsel's unsupported allegations of racism.