In Cruz-Guzman v. State, the Minnesota Supreme Court held that separation of powers principles did not prevent the judiciary from ruling on whether the Minnesota Legislature violated its constitutionally mandated duty to ensure an equal education. The court reversed the Minnesota Court of Appeals’ decision, which held that the question of the legislature’s compliance regarding education was a political question.
As Cruz-Guzman decided, courts have and must continue to have a role in education and maintain the right to education. In order to demonstrate the importance of the court’s involvement in education segregation, this note begins by discussing the role of education and recalling the history of segregated education and its impact in the United States. The note then turns to an overview of federal cases that involved education and several state cases that continue to have an impact on education litigation. A discussion of education clause cases in Minnesota follows. Next, the note discusses justiciability, the political question doctrine, and the judiciary’s jurisdiction and its relation to education clause litigation.
The Cruz-Guzman decision and dissent are discussed afterwards. After providing examples of various state courts that have decided education clause cases and state courts that held the issue to be nonjusticiable, this note argues that Minnesota, because of Cruz-Guzman, is a middle ground between the two extremes of state-court approaches as it recognizes the judiciary’s role while preserving the separation of powers. State courts should look to Minnesota’s approach when deciding justiciability and jurisdictional issues in education cases because Cruz‑Guzman gives the appropriate deference to the legislature while ensuring the court maintains its role to hear constitutional challenges to the legislative action.
Finally, this note discusses why courts should enter the field of education segregation cases. While few courts have found education clause cases to be nonjusticiable, there are benefits to courts extending jurisdiction and rejecting the political question doctrine in order to hear claims regarding segregation in schools. The Minnesota Supreme Court, by giving segregation claims their due regard in Cruz-Guzman, set an example for courts in other states.