Montana

In late 2012, the Montana Quality Education Council (MQEC) filed MQEC v. State, claiming that the state was out of compliance with the funding statute enacted to remedy its constitutional violation in the Columbia Falls case. In 2012, the parties and the court signed a Consent Decree, in which the state pledged to provide the 2.43% inflation adjustment to funding that plaintiffs sought. The Decree also stated that “Economic hardship or a change in financial circumstances of the State shall not serve as a basis for modification of this Consent Decree.”

In 2005, the Montana Supreme Court determined in Columbia Falls Elem. Sch. Dist. v. State that the school finance system did not meet the constitutional requirements of a "basic system of free quality public schools.” The state enacted a new funding system and took steps to address many of the other concerns cited by the court.

In 2008, the Columbia Falls plaintiffs challenged the state’s remedies as insufficient, but, following hearings, the trial court found that the state had made many improvements and closed the case. Plaintiffs did not appeal.

In 1989, in Helena Elem. Sch. Dist. No. 1 v. State the Montana Supreme Court ruled that the state’s education funding system was unconstitutional both because it resulted in inadequate funding, and because spending disparities among the state's school districts "translate[d] into a denial of equality of educational opportunity.”

In 2005, in Columbia Falls Elem. Sch. Dist. 6 v. State, the court found that the state was not providing a “quality” education as mandated by the constitution, relying on the legislature’s failure to define the term quality or to link the funding formula to any factors that might constitute quality, as well as overall deficiencies in the system. The trial court in the case found that the state had violated the provision of the state constitution requiring the state to recognize the distinct and unique cultural heritage of the American Indians and commit in its educational goals to the preservation of their cultural integrity.  The higher court did not review this conclusion because the state did not appeal it, but the state focused on rectifying the situation.

The plaintiffs returned to court, but in 2008, the court declined further relief, finding that the state had made many improvements, such as defining “quality education,” increasing funding, and addressing building deterioration, and was continuing to work toward addressing remaining problems.

“(1) It is the goal of the people to establish a system of education which will develop the full educational potential of each person. Equality of educational opportunity is guaranteed to each person of the state.
(2) The state recognizes the distinct and unique cultural heritage of the American Indians and is committed in its educational goals to the preservation of their cultural integrity.
(3) The legislature shall provide a basic system of free quality public elementary and secondary schools. The legislature may provide such other educational institutions, public libraries, and educational programs as it deems desirable. It shall fund and distribute in an equitable manner to the school districts the state's share of the cost of the basic elementary and secondary school system.”  Mont. Const., art. X § 1.

In Helena Elem. Sch. Dist. No. 1 v. State, the Montana Supreme Court concluded “that the plain meaning of the second sentence of subsection (1) is that each person is guaranteed equality of educational opportunity. The plain meaning of that sentence is clear and unambiguous.” 769 P.2d 684, 689 (Mont. 1989).  The court further wrote that “the guarantee of equality of educational opportunity applies to each person of the State of Montana, and is binding upon all branches of government whether at the state, local, or school district level.” Id. at 690.  The court established that “fiscal difficulties in no way justify perpetuating inequities.” Id.

The court also noted that the Montana School Accreditation Standards established by the State Board of Public Education were "minimum standards upon which quality education must be built," but did “not fully define either the constitutional rights of students or the constitutional responsibilities of the State of Montana for funding its public elementary and secondary schools.” Id. at 692.

In Columbia Falls Elem. Sch. Dist. 6 v. State, the court deferred to the legislature to define a "quality public education" as that term is used in the state constitution, as a “reference point from which to relate funding to relevant educational needs." 109 P.3d 257, 262 (Mont. 2005). The Court held that an adequate education must include state curriculum and learning standards: "Unless funding relates to needs such as academic standards, teacher pay, fixed costs, costs of special education, and performance standards, then the funding is not related to the cornerstones of a quality education."  Id.

The court also commented that “a “system” of education includes more than high achievement on standardized tests.” Id. at 263.

Montana Statutes

Montana Administrative Code

Montana Department of Education