Horne v. Flores (SCOTUS 2009), 557 U.S. 433

Summary

The Supreme Court held that the Arizona Superintendent of Public Instruction has standing to challenge the district court orders because he is a named defendant adjudged in violation of the Equal Educational Opportunities Act (EEOA) and the injunction runs against him. It ruled that the lower courts misapplied Federal Rule of Civil Procedure 60(b)(5) by using an overly strict standard and framing too narrow an inquiry fixated on incremental ELL funding, when the proper flexible approach asks whether changed circumstances—Arizona's adoption of structured English immersion, enactment of the No Child Left Behind Act, structural and managerial reforms in Nogales, and overall funding increases—show the State fulfilling its EEOA obligation by other means. The Court further held that the statewide extension of the injunction lacked supporting findings, that the attorney general's state constitutional uniformity concern could not justify it, and that the injunction should be vacated beyond Nogales unless a statewide violation is found; it reversed and remanded for that analysis. Justice Breyer, joined by Justices Stevens, Souter, and Ginsburg, dissented, contending that resource adequacy was the heart of the statutory violation, that the lower courts fairly considered every claimed change, and that the majority distorts Rule 60(b)(5) by importing an ill-fitting institutional-reform framework.

Holding

Whether the Superintendent of Public Instruction has standing to challenge the lower courts' denial of Rule 60(b)(5) relief.. Yes. The superintendent has standing because he is a named defendant, the declaratory judgment held him in violation of the EEOA, and the current injunction runs against him; because at least one petitioner has standing, the Court did not consider whether the Legislators also have standing.

Whether the Court of Appeals applied the correct Rule 60(b)(5) standard.. No. Its standard was too strict—treating situations warranting relief as 'likely rare' and requiring changes to 'sweep away' the incremental funding determination—and its federalism reasoning was flatly incorrect, since contrary positions among state actors elevate rather than lessen federalism concerns, making a flexible approach critical.

Whether Rule 60(b)(5) relief requires petitioners to show satisfaction of the 2000 order through increased incremental ELL funding.. No. Satisfaction of an earlier judgment is only one of three independent enumerated grounds; petitioners may obtain relief on the independent ground that prospective enforcement is 'no longer equitable,' which requires ascertaining whether ongoing enforcement is supported by an ongoing EEOA violation rather than solely whether the incremental-funding deficiency was cured.

Which changed circumstances the lower courts must examine on remand as potential grounds for Rule 60(b)(5) relief.. At least four: (i) Nogales' implementation of structured English immersion, on which further factual findings are required; (ii) Congress' enactment of NCLB, which—though NCLB compliance will not necessarily constitute 'appropriate action' under the EEOA—is probative in four principal respects; (iii) structural and management reforms in Nogales, which may achieve EEOA-compliant programming without increased incremental funding; and (iv) overall increases in education funding, whose sufficiency the Court of Appeals erroneously foreclosed in 'clear legal error.'

Whether the District Court's entry of statewide relief was justified.. Conditionally no. The record contains no factual findings or evidence that any district other than Nogales failed to provide equal educational opportunities to ELL students, and the former attorney general's concern that a 'Nogales only' remedy would violate the Arizona Constitution's uniform-funding requirement is a state-law question for state authorities that cannot justify a statewide federal injunction; assuming petitioners press the objection on remand, the District Court should vacate the injunction insofar as it extends beyond Nogales unless it concludes Arizona is violating the EEOA on a statewide basis.

Horne v. Flores

Summary

Holding

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