Askew v. Hargrave

Background

In 1968 Florida passed a new school-financing law that tied state aid to local property taxes and limited those local taxes for schools to 10 mills in most districts. Parents and schoolchildren from poorer, property-poor counties sued, saying the 10-mill limit produced less money per child in their counties and therefore discriminated against them. A federal three-judge court granted summary judgment for the plaintiffs, declared the law unconstitutional, and barred the state from withholding funds. A separate state court case raising Florida constitutional challenges was later filed.

Reasoning

The high Court said the federal trial court should have considered that the state-court case might resolve the dispute without deciding the federal equal-protection question. The Court explained that earlier federal-case rules relied on by the district court were not controlling here because the state case raises primarily state-law claims. The Court also found the record used for summary judgment inadequate: the pleadings and a confirming affidavit did not fully show how the statewide financing program operated or whether state aid made up for the 10-mill limit. For these reasons, the Court vacated the judgment and sent the case back for further proceedings and fact-finding.

Real world impact

The decision means more courtroom fact-finding before any final decision about the law’s fairness. A state-court ruling on Florida’s Constitution could make a federal ruling unnecessary. Meanwhile, the previous federal injunction is no longer the final word, and disputes over how much money each district gets will remain unresolved until the record is developed and courts consider both state and federal claims.

Dissents or concurrances

Justice Black agreed with the Court’s judgment and with the opinion’s discussion that the record was inadequate and the case needed further proceedings.