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I.L., et al.v.The State Of Alabama, et al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.11-15464
DecidedJanuary 10, 2014
Reporter739 F.3d 1273
JudgesCircuit Judges Jordan and Anderson, and District Judge Hornby; Jordan authored the opinion
Tags
CivilCivil RightsEducation LawTax LawConstitutional LawStandingStatutory InterpretationVacaturRemand
Case Summary

Black and white children from rural Alabama counties challenged constitutional provisions governing property-tax limits and assessment ratios, alleging that the system reflected historic racial discrimination and left their public schools underfunded. The Eleventh Circuit held that the plaintiffs had standing to challenge the assessment-ratio provisions but not the millage caps. Removing the caps might not lead lawmakers or voters to raise tax rates or revenues, so the requested injunction would not likely redress the alleged injury. The court dismissed those claims without prejudice. The court also held that the Tax Injunction Act did not bar the challenge to the assessment ratios because success would increase, rather than reduce, state tax receipts, and Alabama withdrew its separate comity defense on appeal. On the merits, the court affirmed the finding that the assessment system in Amendments 325 and 373 was financially, not racially, motivated. Although Alabama’s history and the evidence could have supported a contrary finding, the district court’s conclusion was permissible under clear-error review. The judgment was therefore affirmed in part and vacated and remanded in part with instructions to dismiss the millage-cap claims without prejudice.

Opinion

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