King County v. Seattle School District No. 1

Background

A Seattle-area school district sued King County after the county received federal payments tied to a nearby forest reserve. Congress had directed 25% of money from each forest reserve be paid to the State to be used for public schools and public roads in the counties where the reserve sits. Washington law required the State to pass the money to county treasurers and authorized county commissioners to spend it for schools and roads. Over several years the county sometimes put all the money into roads and sometimes split it, and the school district sought its claimed share based on student attendance.

Reasoning

The Court asked whether the federal law forced an equal annual division between schools and roads or left the choice to the State and its counties. It concluded the statute does not require an equal split and that once the money is paid to the State it belongs to the State to spend as its legislature prescribes. The Court also explained that, even if the money were thought to be held in trust for the stated purposes, only Congress could enforce how the State executes that obligation. For those reasons the Court reversed the lower courts’ judgment in favor of the school district and refused to let the district force a distribution.

Real world impact

The decision means local school districts cannot sue counties to force fixed shares of these federal forest payments. States and counties keep discretion over how to allocate the funds under state law, and any federal enforcement of the original congressional intent would have to come from Congress rather than individual districts.