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Heber Springs School District v. West Side School District
Citations: 269 Ark. 148; 599 S.W.2d 371; 1980 Ark. LEXIS 1492Docket: 80-11
Court: Supreme Court of Arkansas; June 2, 1980; Arkansas; State Supreme Court
Frank Holt, Justice, addresses a legal appeal stemming from Thomas v. Foust, which invalidated Act 407 of 1965 as local legislation violating Amendment 14 of the Arkansas Constitution. In response, the legislature passed Act 390 of 1979, which the trial court has since declared invalid. The case involves the West Side School District, which was divided by the Greers Ferry Dam, resulting in the Beloit Bay/Eden Isle (BB/EI) area. In previous years, students from this area attended the Heber Springs District under a tuition agreement, with West Side paying $625 per student, while receiving state funding and local property tax revenue. The conflict arose when the BB/EI area sought annexation to the Heber Springs District under Act 390, which allows annexation for severed districts with specific conditions, including a reservoir size of over 12,000 acres and a round trip travel distance exceeding 35 miles. This annexation would reduce West Side's revenue. The appellees challenged the constitutionality of Act 390, asserting that its classifications are arbitrary and lack a reasonable connection to the act's objectives. The trial court agreed, noting that the relationship between the reservoir's existence, its size, and the travel distance to school does not reasonably relate to the act's purpose. The appeal examines whether the trial court erred in finding Act 390 unconstitutional. It cites precedent affirming a presumption of constitutionality for legislative enactments and the legislature's discretion in establishing school districts based on varying demographics and geography. The ruling emphasizes the need for classifications within legislation to have a reasonable relation to its intended purpose. Population density, national wealth, road systems, and terrain characteristics are valid factors for legislative classification. The legislature's power to classify is supreme as long as it is reasonable and uniformly applied. Previous legislation, such as Act 407 of 1965, allowed for annexation of school districts under specific conditions but was deemed arbitrary due to a nonprospective time limitation. Act 390 of 1979, which permits annexation of portions of school districts severed by a large reservoir, lacks this limitation and addresses issues like transportation difficulties and administrative confusion. It allows for crossing county lines, a significant improvement over the prior act, and is not limited in its application. The classification in Act 390 is reasonable and aligns with legislative goals for educational benefit. The court rejected arguments claiming the act violates the equal protection clause of the 14th Amendment. The issue of property tax responsibilities related to the annexed area is to be determined upon remand. The appellee contended that Act 390 violates the due process clause, but the court noted that school districts are generally state creations and less protected under the clause. Act 390 includes provisions for financial reimbursement to affected districts due to annexation. The decision was reversed and remanded, with some justices dissenting.