Rajala v. Joliet Grade School District No. 86

Citations: 107 Ill. App. 2d 410; 246 N.E.2d 74; 1969 Ill. App. LEXIS 1047Docket: Gen. No. 66-114

Court: Appellate Court of Illinois; March 26, 1969; Illinois; State Appellate Court

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Bruce Rajala, represented by his mother, initiated a lawsuit against Joliet Grade School District No. 86 in Will County Circuit Court, alleging violations of the Armstrong Act, which mandates the creation and adjustment of school attendance units to prevent segregation based on race, color, or nationality. Rajala sought a declaratory judgment and an injunction, claiming that 21 of 26 school units were predominantly white or predominantly Black, with no actions taken to address this segregation. The school district moved to dismiss the complaint, arguing that Rajala had not exhausted the required administrative remedies as outlined in section 22-19 of the Illinois Revised Statutes. This section mandates filing a complaint with the Superintendent of Public Instruction, which includes a hearing process and potential court intervention by the Attorney General if necessary. The trial court granted the dismissal, confirming that Rajala did not follow the administrative procedure. During the appeal, it was revealed that a related case (Tometz v. Board of Education) was pending in the Illinois Supreme Court, which could impact the outcome of this case.

A constitutional challenge to the Armstrong Act was raised, specifically regarding whether plaintiffs must exhaust administrative remedies outlined in section 22-19 of the Illinois statutes before filing enforcement actions. The trial judge determined that section 22-19 did not constitute an enforceable administrative remedy, as the Superintendent of Public Instruction lacked authority to grant the relief sought, referencing McNeese v. Board of Education. Subsequently, actions in the current case were postponed until the Illinois Supreme Court resolved the Tometz case, which initially deemed the Armstrong Act unconstitutional but later affirmed its constitutionality after a rehearing. The court's later opinion did not address the exhaustion of administrative remedies. The appellee school district argued that the School Code provides a comprehensive administrative process for addressing discrimination, asserting legislative intent for administrative procedures to precede court actions. This position is supported by precedents requiring exhaustion of administrative remedies under the Illinois School Code, which the appellant did not contest. It was further claimed that the administrative remedy could effectively address the plaintiff's claims if proven valid. Additionally, it was argued that McNeese only exempts exhaustion in cases involving federal constitutional rights and does not apply to state statute actions like the Armstrong Act. The legislative history indicated that the administrative procedure was designed to be a necessary initial step in tackling segregation issues, emphasizing the Superintendent's specialized knowledge in this area.

Appellants assert three key points regarding the role of the Superintendent of Public Instruction in school desegregation. First, they argue that legislative intent does not envision the Superintendent coordinating desegregation efforts among school boards. Second, they contend that the Armstrong Act does not require the Superintendent to ensure statewide racial balance, as this responsibility lies with the school boards, which can act independently unless a complaint is filed. Third, they reference the Tometz decision, which upheld the Armstrong Act's constitutionality, suggesting it supports their position by indicating there is no mandated involvement of the Superintendent prior to court actions regarding desegregation.

Appellants maintain that local school districts possess the necessary practical knowledge to manage desegregation effectively, rather than relying on the Superintendent, who lacks insight into localized issues. They acknowledge the general principle that administrative remedies should be exhausted before court intervention, but argue that this requirement does not apply if such remedies cannot provide the necessary relief, as the Superintendent lacks the authority to grant the relief sought. 

While the court does not resolve these contentions, it emphasizes adherence to the Tometz decision, which implies that section 22-19 of the Act does not dictate exclusive administrative remedies before litigation can occur. Consequently, the Circuit Court of Will County's order is reversed, and the case is remanded with instructions to vacate the dismissal and proceed accordingly.