School District of Waukesha v. School District Boundary Appeal Board

548 N.W.2d 122, 201 Wis. 2d 109, 1996 Wisc. App. LEXIS 384
CourtCourt of Appeals of Wisconsin
DecidedMarch 27, 1996
Docket95-0905
StatusPublished
Cited by2 cases

This text of 548 N.W.2d 122 (School District of Waukesha v. School District Boundary Appeal Board) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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School District of Waukesha v. School District Boundary Appeal Board, 548 N.W.2d 122, 201 Wis. 2d 109, 1996 Wisc. App. LEXIS 384 (Wis. Ct. App. 1996).

Opinion

SNYDER, J.

The School District Boundary Appeal Board (SDBAB) and the residents of the Weston Hills subdivision (the residents) appeal from a trial court order reversing a decision of the SDBAB on the basis that the decision was arbitrary and capricious. Because the SDBAB decision was the result of a rational process, we conclude that the trial court's finding was the result of impermissibly expanding the scope of review. We therefore reverse the trial court and reinstate the decision of the SDBAB.

The Weston Hills subdivision lies entirely within the city of Brookfield. However, since 1962 it has been attached to the Waukesha School District (Waukesha). The residents filed a petition for reorganization with the school boards of Waukesha and the Elmbrook School District (Elmbrook). The petition sought to detach the property occupied by the subdivision from Waukesha and attach it to Elmbrook. 1

The Waukesha School Board held a public hearing on the petition and one week later denied the detachment. The effect of this was to deny the proposed *113 reorganization because each affected school district must adopt a resolution ordering the detachment and attachment for the reorganization to take place. See § 117.12(3), Stats. Elmbrook subsequently passed an advisory resolution which indicated its willingness to accept the attachment of the Weston Hills subdivision.

The Waukesha School Board's denial was appealed by the residents to the SDBAB. The SDBAB received a written record and heard presentations from proponents and opponents of the petition. The SDBAB then ordered the property detached from Waukesha and attached to Elmbrook. Waukesha appealed this decision to the trial court. After finding that the decision of the SDBAB was arbitrary and capricious, the trial court reversed the SDBAB and ordered the property returned to Waukesha. This appeal followed.

School district reorganization is a legislative policy-making function, and as such has been delegated by the legislature to local boards. Joint Sch. Dist. No. 1 v. State Appeal Bd., 56 Wis. 2d 790, 794, 203 N.W.2d 1, 4 (1973). The merits of a school district reorganization is a legislative determination and does not raise justicia-ble issues of fact or law. Id. The only issues to be considered are whether the reorganization authority acted within its jurisdiction and whether its determination was arbitrary or capricious. 2 Id. at 795, 203 N.W.2d at 4.

While case law suggests that the scope of review is well settled and narrowly defined, Waukesha maintains that the scope of this court's review powers has been expanded. The school district argues that the enactment of § 117.15, Stats., with its mandated con *114 siderations, has specifically circumscribed the power and actions of the appeal board. 3 Therefore, Waukesha *115 argues, this court's review is to "ensure that the 'winnowing and sifting' process of all of the criteria enumerated under § 117.15, Stats., actually occurred, in the manner described, and that a decision under this section was made in a non-arbitrary or capricious manner." Waukesha maintains that "[i]t is clear that in light of these statutory revisions, the discretion vested in appeals boards by the legislature has been limited, and the scope of judicial review has been expanded to that extent."

We disagree that the enactment of a statute which includes a "laundry list" of factors the SDBAB must consider expands the scope of judicial review. The state supreme court addressed this very argument after an earlier statutory revision of the school board's reorganization authority. See Joint Sch. Dist. No. 1, 56 Wis. 2d at 794, 203 N.W.2d at 3-4. There the court stated:

Although the principal cases discussing the nature of [the function of a school board reorganization authority] antedate the present statute, we are satisfied that the current statute merely codifies previous legislative directives and in no way . . . affect[s] the nature of the legislature's grant of power to school board reorganization authorities. These cases make it clear that school district reorganization is a legislative policy-making function, which the legislature has delegated to local boards and to the state superintendent of public instruction.
As a consequence of these holdings, we have concluded that the merits of a school district reorganization is a legislative determination of public policy questions which does not raise justiciable issues of fact or law. Since the issues are legislative *116 in nature, we have stated that even a delegation to this court by the legislature of the authority to make a full review would be contrary to the doctrine of separation of powers.

Accordingly, on an appeal to the courts . . . the only issues to be considered are whether the reorganization authority acted within its jurisdiction and whether its order was arbitrary or capricious.

Id. at 794-95, 203 N.W.2d at 3-4 (citations omitted). Although this language predates the enactment of the current statutory authority for the reorganization of school districts, see § 117.15, STATS., we conclude that the addition of particular factors for the SDBAB to consider has not changed the standard of judicial review of that agency's actions.

On appeal, this court reviews the decision of the SDBAB, not that of the trial court. See St. Paul Ramsey Med. Ctr. v. DHSS, 186 Wis. 2d 37, 43, 519 N.W.2d 681, 683 (Ct. App. 1994). Because there is no dispute as to the jurisdiction of the SDBAB, we confine our review to the issue of whether the order of the SDBAB evinced arbitrary or capricious action. See Joint Sch. Dist. No. 1, 56 Wis. 2d at 797, 203 N.W.2d at 5. Such action occurs when the findings of the agency are unreasonable or without a rational basis. Id. An action is arbitrary if it is the result of an "unconsidered, wilful and irrational choice" and not the result of the "winnowing and sifting" process. Id. (quoted source omitted).

While the SDBAB is statutorily bound to consider all of the factors enumerated in § 117.15, STATS., the agency may, in its discretion, consider information *117 from other sources as well. See Joint Sch. Dist. No. 2 v. State, 71 Wis. 2d 276, 284, 237 N.W.2d 739, 743-44 (1976). It is proper for the SDBAB to consider "matters within its knowledge and expertise in the field of educational policy." Joint Sch. Dist. No. 2 v. State Appeal Bd., 83 Wis.

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548 N.W.2d 122, 201 Wis. 2d 109, 1996 Wisc. App. LEXIS 384, Counsel Stack Legal Research, https://law.counselstack.com/opinion/school-district-of-waukesha-v-school-district-boundary-appeal-board-wisctapp-1996.