State of Alaska, Michael Hanley

Summary

The Alaska Supreme Court reversed the superior court's summary judgment ruling and held that the required local contribution under Alaska's public-school funding formula does not violate the dedicated-funds, appropriations, or governor's-veto clauses. The court reasoned that the contribution is part of a longstanding state-local cooperative school-funding program that the constitutional convention did not intend to treat as a state tax or license, and that the contribution neither withdraws money from the state treasury nor constitutes an appropriation bill. The court remanded for entry of judgment in favor of the State. WINFREE, Justice, concurring, agreed that the Borough had not overcome the presumption of constitutionality but declined to join the majority's dedicated-funds analysis and questioned whether the public-schools clause permits the required local contribution.