ARMSTRONG-RINGSTED v. LAKELAND AREA EDUC.
| Decision Date | 17 February 1999 |
| Docket Number | No. 97-346.,97-346. |
| Citation | 597 N.W.2d 776 |
| Parties | ARMSTRONG-RINGSTED COMMUNITY SCHOOL DISTRICT, Appellant, v. LAKELAND AREA EDUCATION AGENCY and The Board of the Lakeland Area Education Agency, Appellees. |
| Court | Iowa Supreme Court |
Harold W. White of Fitzgibbons Law Firm, Estherville, for appellants.
Rick Engel, West Des Moines, for appellees.
Considered by HARRIS, P.J., and LARSON, CARTER, NEUMAN, and TERNUS, JJ.
The Armstrong-Ringsted Community School District (Armstrong-Ringsted), appeals from a district court's judgment upholding the Lakeland Area Education Association's (area education agency) dismissal of its petition for reorganization of the Lincoln Central and Armstrong-Ringsted School Districts. Armstrong-Ringsted argues that the district court erred in affirming the area education agency's action because its petition complied with all statutory requirements under chapter 275 of the Iowa Code and was consistent with the area education agency's reorganization plan. Armstrong-Ringsted also contends that the area education agency was unduly influenced by another petition for reorganization, which, it alleges, was later improperly granted. After reviewing the record and considering the arguments presented, we affirm the judgment of the district court.
In April 1995 petitioners from both the Lincoln Central and Armstrong-Ringsted School Districts submitted a petition for reorganization to the area education agency. That petition, signed by 126 residents of the Lincoln Central district and 393 residents of the Armstrong-Ringsted district, sought to combine the entirety of those two districts into one newly organized district. After holding a public hearing, the area education agency dismissed that petition on June 19, 1995.
During the pendency of the Lincoln Central and Armstrong-Ringsted merger proposal, another petition had been filed with the area education agency involving a proposed merger of the Lincoln Central and Estherville School Districts. The agency had previously approved a similar merger proposal, but at that time, that proposed merger failed to win the support of the voters. After the area education agency had denied the proposed merger of the Lincoln Central and Armstrong-Ringsted districts, a renewed petition for a merger of the Lincoln Central district with the Estherville district was acted on affirmatively by the area education agency and approved by the voters. Following the approval of that plan, the Lincoln Central School District withdrew from this litigation, which was then pending in the district court.
Armstrong-Ringsted contends that, because its reorganization petition complied with chapter 275 of the Iowa Code and the area education agency's reorganization plan, the area agency was required to approve the petition and put it to a popular vote. The area education agency's reorganization plan was developed in 1987 in order to assist the agency in the event it was presented with a reorganization petition. The plan required that a proposed district meet three provisions. These provisions were (1) the proposed district has an enrollment base sufficient to support an adequate education program, (2) the proposed district shall constitute a reasonable geographic unit that does not present unduly difficult transportation or communication problems, and (3) the proposed district remain viable for the foreseeable future and stand the test of time. Both Armstrong-Ringsted's superintendent and the area education agency's administrator agreed that the proposed merger between Armstrong-Ringsted and Lincoln Central would meet these three criteria. Armstrong-Ringsted believes that this entitles its proposed district to approval.
We have developed several principles that apply when reviewing school district reorganization decisions. See Hedrick Community Sch. Dist. v. Southern Prairie Area Educ. Agency, 433 N.W.2d 746, 750 (Iowa 1988). We consider only legal questions and cannot substitute our judgment for that of the education authorities regarding the wisdom and practicability of the proposed reorganization. Id. Our review is limited in this way because reorganization is a legislative, not judicial, process. Id. We will only interfere with these local legislative matters when it appears that an education agency has "exceeded its jurisdiction or has taken an action that is arbitrary, unreasonable or unsupported by substantial evidence in the record." Id. at 750-51. We have defined arbitrary or unreasonable action as action that is unconsidered, willful, or without rational basis. Id. at 751.
To continue reading
Request your trial
-
State v. ESTHERVILLE LINCOLN CENTRAL, 98-353.
...School District. We affirmed the district court's decision in February 1999. See Armstrong-Ringsted Community Sch. Dist. v. Lakeland Area Educ. Agency, 597 N.W.2d 776 (Iowa 1999). The legal contention of the relators is that the same geographical area cannot be made subject to two pending r......
-
E. Cent. Cmty. Sch. Dist. v. Miss. Bend Area Educ. Agency
...a result, we found substantial compliance with the statutory requirements. Id. Finally, in Armstrong-Ringsted Community School District v. Lakeland Area Education Agency, 597 N.W.2d 776 (Iowa 1999), we considered a case in a much different posture. In Armstrong-Ringsted, residents of a scho......