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Robinson v. Kansas
No. 00-3315, 00-3332 (10th Cir. July 9, 2002) ; Clearinghouse Number: 54805
Description
Kansas State Officials Are Not Immune from Suit Challenging State’s School Financing Scheme
Abstract
The Tenth Circuit has held that the Ex parte Young doctrine is
applicable to permit suit against state officials pursuant to
section 1983 for alleged violations of Title VI and the Fourteenth
Amendment. Plaintiffs contend the Kansas state school financing
system, through a provision for "low enrollment
weighting" and "local option budgets," results in
less funding per pupil in schools where minority students, students
who are not of United States origin, and students with disabilities
are disproportionately enrolled. Plaintiffs contend that the School
District Finance and Quality Performance Act, Kan. Stat. Ann.
§§ 72-6405 to -6440 has a discriminatory disparate impact
on such students in violation of the implementing regulations of
Title VI of the 1964 Civil Rights Act, 42 U.S.C. § 2000d-1,
the Rehabilitation Act of 1973, 29 U.S.C. §§ 701 et seq.,
and plaintiffs' rights to due process and equal protection
under the Fourteenth Amendment. Defendants contended that
plaintiffs’ suit is barred by the Eleventh Amendment.
Defendants maintained that Congress did not abrogate their Eleventh
Amendment immunity, that they did not waive such immunity, and that
the relief sought against state officials named as defendants does
not fall under the Ex Parte Young doctrine. The district
court denied defendants’ motion to dismiss, and they
appealed. Affirming, the court of appeals held that, by accepting
federal financial assistance as specified in 42 U.S.C. §
2000d-7, states and state entities waive sovereign immunity from
suit. Finding that defendants are not protected by the Eleventh
Amendment, pursuant to the Ex parte Young doctrine, the
court affirmed the district court’s order denying
defendants’ motion to dismiss.
