Pack v. State ROPE Amicus Brief Regarding Constitutionality of HB3399

5/21/2018 Pack v. State ROPE Amicus Brief Regarding Constitutionality of HB3399

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I. STANDING

Petitioners lack standing to challenge the constitutionality of HB 3399 because

they have not yet been affected by the Legislature's enactment of HB 3399. Petitioners'

Brief in Support of Application to Assume Original Jurisdiction and Petition for Writ and

Declaratory Relief (hereinafter, Petitioner's BRIEF), Page 4, states that "standing requires

an injury, a causal nexus, and a likelihood that the injury can be redressed"; however, it

fails to identify any injury, causal nexus, or injury that can be redressed.

Petitioners' complaints target Section 4 of HB 3399, which will not apply until

Oklahoma's education standards are re-written, and that could take up to two years. This

case is not ripe at this time for this set of Petitioners.

The practical view is that, with or without HB 3399, Petitioners will have to do as

directed by the Legislature, which does not allow them to claim any harm.

Petitioners' BRIEF, Page 4, claims that each Petitioner stands "to be injured by the

Legislature's improper encroachment on the Constitutional and Executive authority of the

Board." This claim is unproven, speculative and fails to establish standing.

Petitioners state that "[The Petitioners who are teachers] should be empowered to

teach standards promulgated by the educators at the Board, without coercive Legislative

intrusion." (Petitioners' BRIEF, PP. 4 - 5). Teachers will have a duty to teach the

standards, period. What they erroneously describe as "coercive Legislative intrusion,"

will occur before the teachers receive the standards and is required by Art XIII, Section 5

of the Oklahoma Constitution. Educators would be expected to welcome any input that

could strengthen the standards. Surely, they do not claim that only members of the Board

have the interest and ability to formulate standards.



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Petitioners state that their children "should be instructed and tested under

constitutionally codified standards free from excessive Legislative intrusion."

(Petitioners' BRIEF, P. 5). The standards contained in HB 3399 have been

constitutionally codified: The Oklahoma Constitution (Art. XIII, 5) requires the

Legislature to prescribe every power and every duty of the Board of Education. It is that

power of the Legislature that allows the Board to draft and approve subject matter

standards, subject to Legislative approval. If this authority of the Legislature is

"excessive," then Petitioners should seek a change to the Constitution.

Petitioners state that "Board members . . . should be allowed to fulfill their

constitutional responsibility to supervise instruction in public schools without coercive

interference by the Legislature into the drafting of subject matter standards." (Petitioners'

BRIEF, P. 5). Board members' "supervision of instruction[,]" (Art. XIII, 5) which is to

oversee teaching, is not impacted by HB 3399. Subject matter standards are Public

Policy and must be codified by the Legislature as general law,1which is necessary in

order for the Legislature to provide education policy to the Board.

Petitioners erroneously identify the Constitutional responsibility of the Legislature

as "coercive interference by the legislature." They also state, "Given the public

importance of this matter, Petitioners have standing to challenge the constitutionality of

HB 3399." (Petitioners' BRIEF, P. 5) Yes, this matter does have public importance;

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"General Law. A law that affects the community at large. A general law as contradistinguished

from one that is special or local, is a law that embraces a class of subjects or places, and does not omit any

subject or place naturally belonging to such class. A law, framed in general terms, restricted to no locality,

and operating equally upon all of a group of objects, which, having regard to the purposes of the legislation,

are distinguished by characteristics sufficiently marked and important to make them a class by themselves,

is not a special or local law, but a general law. A law that relates to a subject of a general nature, or that

affects all people of state, or all of a particular class." Black's Law Dictionary, P. 471, (6th Ed. 1991).



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however, standing is not based upon importance. It requires an injury, a causal nexus,

and a likelihood that the injury can be redressed, which are notably absent from

Petitioner's BRIEF. Petitioners' case must be dismissed.

II. STANDARD OF REVIEW

InDobbs v. Board of County Com'rs of Oklahoma County, 1953 OK 159, 0, 257

P.2d 802, __, this Court stated,

1. Our Constitution vests in the Legislature the supreme power to enactlaws to meet the needs of the state, and its acts should be upheld unless

plainly and clearly within the express prohibitions and limitations fixed by

the Constitution.

2. In passing upon the constitutionality of an act of the Legislature all

pertinent sections of the Constitution should be considered together inarriving at a correct interpretation.

3. In considering the constitutionality of an act of the Legislature, every

presumption is to be indulged in favor of the validity of the act unless its

invalidity is made to appear beyond a doubt. It is the duty of the court touphold an act of the Legislature unless it clearly violates the Constitution,

and if the language of the act is susceptible of a meaning that will remove

the objection to its validity, such interpretation should be adopted. It

should never be assumed that the Legislature intended to violate theConstitution. (Underline added).

This court also provided direction if there is any doubt as to the Legislature's

power to act in any given situation:

When the legislative purpose has been declared in plain and unmistakable

language, it is not within the province of the court to interpose contrary

views of what the public need demands . . . .

We do not look to the Constitution to determine whether the Legislature is

authorized to do an act but rather to see whether it is prohibited.

Tate v. Logan,1961 OK 136, 14-19, 362 P.2d 670, __. (Underline added).



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III. SEVERABILITY & REVOKABILITY

Pages 13- 5 of Petitioners' BRIEF erroneously attempt to explain why HB 3399 is

unconstitutional by describing certain sections of HB 3399 that prevent the severability of

Section 4. Rather than to search to find some rationale for declaring HB 3399

unconstitutional,

it is the duty of the court to uphold [HB 3399] unless it clearly violates the

Constitution, and if the language of the act is susceptible of a meaning that

will remove the objection to its validity, such interpretation should beadopted.

Dobbs v. Board of County Com'rs of Oklahoma County, 1953 OK 159, 0, 257

P.2d 802, __,

Petitioners' questions refer to Section 4 of HB 3399; however, they devote

several pages attempting to show why severability of Section 4 is not possible in order to

ask the Court to declare the entire bill unconstitutional. This request must be denied. If a

provision of an act is found to be unconstitutional, "the remaining provisions shall remain

valid" unless certain exceptions apply.2

75 O.S. 11a. Application of these exceptions is

demonstrated in Fent v. Contingency Review Board, 2007 OK 27, 17- 20, 163 P.3d

512, __.

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2 "For any act enacted on or after July 1, 1989, unless there is a provision in the act that the act or any

portion thereof or the application of the act shall not be severable, the provisions of every act or application

of the act shall be severable. If any provision or application of the act is found to be unconstitutional and

void, the remaining provisions or applications of the act shall remain valid, unless the court finds:

a. the valid provisions or application of the act are so essentially and inseparably connected with, and so

dependent upon, the void provisions that the court cannot presume the Legislature would have enacted the

remaining valid provisions without the void one; or

b. the remaining valid provisions or applications of the act, standing alone, are incomplete and are

incapable of being executed in accordance with the legislative intent. . . . 75 O.S. 11a.



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Section 4 of HB 3399 is an addition to Title 70 of the Oklahoma Statutes that,

among other things, codifies the Constitutionally required oversight of the Board by the

Legislature. The other sections of HB 3399 could have been enacted as policy, without

the Legislative oversight provided in Section 4. The intent of HB 3399 is to remove

Common Core from Oklahoma Schools, and Section 4 is included to enforce and assure

that removal. Clearly, the Legislature would have enacted the other sections, without

Section 4, in order to remove Common Core from Oklahoma schools. The importance of

removing Common Core is evidenced by the inclusion of Section 4. Furthermore, the

removal is necessary: Finding HB 3399 unconstitutional is, itself, unconstitutional.

Returning Common Core to Oklahoma unconstitutionally delegates authority that

is constitutionally vested in the Legislature to anonymous, unaccountable out-of-state

entities, an action not imagined by the Oklahoma Constitution.

IV. INTRODUCTION

This case questions the balance of power between the Oklahoma Legislature

(hereinafter, "Legislature") and the State Board of Education (hereinafter, "Board").

Our Constitution vests in the Legislature the supreme power to enact laws

to meet the needs of the state, and its acts should be upheld unless plainly

and clearly within the express prohibitions and limitations fixed by theconstitution.

Dobbs v. Board of County Com'rs of Oklahoma County, 1953 OK 159, 0, 257 P.2d 802,

__.

Pursuant to art. XIII, 5 of the Oklahoma Constitution,

"The supervision of instruction in the public schools shall be vested in a

Board of Education, whose powers and duties shall be prescribed by law."



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This "supervision of instruction" language describes supervisory authority in

contrast to the "supreme power" vested in the legislature. Moreover, this "supervision of

instruction" language is followed by the restriction, that the Board of Education is a

board, "whose powers and duties shall be prescribed by law," making clear that the

legislature has ultimate authority over the Board.

"Supervise" means "to take charge of especially on behalf of another." Merriam

Webster, http:www.merriam-webster.com/thesaurus/supervising (emphasis added). The

examples given by Merriam-Webster are clear: supervising "the construction project

while the foreman is in the hospital," and "an experienced hand assigned to supervise a

novice seaman." The concept of supervision, as illustrated by these examples, implies a

significant amount of discretion, but it does not connote supreme power of the type

vested in the Oklahoma Legislature. Additionally, "instruction" is defined by Merriam

Webster, http:www.merriam-webster.com/thesaurus/supervising as "to give knowledge

to. . . ." Merriam Webster's examples include, "She instructedus that we were to remain

in our seats" and "The Judge instructedthe jury that they should disregard the testimony

of the last witness." Educators routinely interpret "instruct" as "teach."

There should be no dispute that "prescribed by law" means codified by the

legislature and that the phrase, "whose powers and duties shall be prescribed by law,"

encompasses all powers and all duties of the Board. The plain, clear language of the

Constitution allows the Board to oversee teaching, which does not rise to the level of the

supreme power vested in the legislature and actually requires (as provided by the word,

"shall," in Art. XIII, 5) that all powers and all duties of the Board are subject to the



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controlling influence of the legislature. Consequently, the Board has no power that is not

prescribed by the legislature.

Petitioners inaccurately state that HB 3399 empowers the Legislature to approve,

disapprove, or amend subject matter standards adopted by the Board. (Petitioners'

BRIEF, P. 5). HB3399 does not empower the Legislature, it reserves to the Legislature

the power to codify HB 3399 and to assure that it goes into effect. Additionally, it is the

responsibility of the Legislature to, among other things, prescribe the powers and duties

(all powers and all duties) of the Board. Okla. Const. Art. XIII, 5. The Legislature has

no duty to allow the Board to even participate in the development and adoption of subject

matter standards. However, the approach taken in HB 399 is reasonable and within the

scope of legislative powers laid out in the Constitution and not prohibited thereby.

Rather than the Legislature, it is the Board that is given power by HB 3399,

which, among other things, grants the Board the power to prepare and adopt subject

matter standards, subject to the controlling influence or supervision of the Legislature to

assure the implementation of Public Policy.

In particular, Section 4 of HB 3399 codifies a new section of law, appropriately in

the Oklahoma Statutes at Title 70. Schools. This new section of law mirrors existing

sections of Title 70 by prescribing powers and duties of the Board (The words, "The State

Board of Education shall . . . ," appear profusely throughout Title 70, and are also utilized

in HB 3399, to assign duties to the Board). Title 70 was passed as law by the Legislature,

just as HB 3399 was passed as law by the Legislature. The Board is obligated to obey

HB 3399 just as it has been and continues to be obligated to obey the other provisions in

Title 70.



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Petitioners erroneously attempt to elevate the Board to the level of the Regents of

Higher Education, when the Constitution clearly distinguishes between the Board and the

Regents. The Board is vested with the "supervision of instruction" in the public schools,

subject to any powers and duties prescribed by law. Supervision of instruction (teaching)

refers to oversight of the delivery of the subject matter. It does not extend to the

development of subject matter standards, which are State Policy. The Board of

Education, which is under strict Legislative oversight, contrasts sharply with the

Oklahoma State Regents, who enjoy much broader freedom from Legislative control. The

Oklahoma Constitution, in Art. 13A, 2, states, "The Regents shall constitute a co-

ordinating board of control . . . with the following specific powers: (1) [to] prescribe

standards of higher education applicable to each institution; (2) [to] determine the

functions and courses of study in each of the institutions to conform to the standards

prescribed; (3) [to] grant degrees and other forms of academic recognition . . . ; (4) [to]

recommend to the State Legislature the budget allocations to each institution, and (5) [to]

have the power to recommend to the Legislature proposed fees . . . ." This is not the case

for the Board of Education, which has no power at all, unless prescribed by the

Legislature. Additionally, the Board of Regents is constituted as a "board of control."

The powers of the Regents are clearly described and granted; however, the Board of

Education is described as a "Board of Education, whose powers and duties shall be

prescribed by law." The Constitution firmly places the Board of Education under the

controlling influence of the Legislature: Everything the Board does (powers) and

everything it is required to do (duties) must be prescribed by the Legislature. It is clear

from the plain language of the Oklahoma Constitution that the Regents of Higher



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Education reside in a Constitutionally secured position of independence that is not

provided to the Board of Education. It is no accident that "supervision of instruction" is

not listed among the powers of the Regents, whose functions are comparable to those of

the Legislature. The oversight of teaching is a function below the level of the powers

granted by the Constitution to the Regents.

It is the supreme power of the Legislature, not HB 3399, that gives the Legislature

controlling influence over the powers and duties of the Board, and this influence is

mandatory.

On Page 9 of Petitioners' BRIEF, Petitioners state, "Here, it is not disputed that

the Legislature can set policy for public education. Section 4 [of HB 3399] goes beyond

that, however, and involves the Legislature in the details of carrying out that policy in the

classrooms." This description of Legislative involvement is false: Section 4 reserves for

the Legislature the power to approve, disapprove, or amend the subject matter standards

adopted by the State Board of Education.

Petitioners erroneously claim that art. XIII, 5 protects the Board of Education

from "unwarranted legislative interference." (Petitioners' BRIEF, P. 7). The Oklahoma

Constitution, Art XIII, 5, actually requires the Legislature to prescribe every power and

every duty of the Board, including the oversight of teaching. What Petitioners'

Questions, on Page 2 of their Brief, describe as "infringe on the Constitutional authority

of the Board" and "controlling power over the executive power of the Board" is

Constitutionally required oversight by the Legislature.

Petitioners describe the Board as an "executive branch agency." (Petitioners'

BRIEF, P. 10). They rest this description on the fact that the Board consists of "the



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Superintendent of Public Instruction and six appointees of the Governor." Okla. Const.,

art. XIII, 5. Petitioners fail to mention that the current makeup of the Board is specified

by the Legislature in Title 70 of the Oklahoma Statutes and that the Superintendent of

Public Instruction is the only constitutionally required Board Member. "Until otherwise

provided by law, the Governor, Secretary of State, and Attorney General shall be ex-

officio members of the Board." Okla. Const., art XIII, 5. (Underline added). The

Legislature clearly has the power to enact law that changes the members of the Board or

removes the authority of the Governor to appoint certain members of the Board. The

Legislature codified Title 70 of the Oklahoma Statutes, consequently, the Legislature is

empowered to modify or repeal any part or all of Title 70 as it deems beneficial to the

public weal.

In attempting to argue that the Board is an executive branch agency, Petitioners

falsely claim the "power" of the Board to "[set] substantive standards for learning for

each grade level." (Petitioners' BRIEF, P. 10). As shown previously, the Board has no

power except as prescribed by the Legislature. Also, Petitioners erroneously expand the

"supervision of instruction," which is oversight of teaching, to include the setting of

substantive standards for learning.

Petitioners have based their arguments on partial truths. Yes, the Constitution

states that the supervision of instruction shall vest in the Board. However, the

Constitution also constitutes the Board as a board, "whose powers and duties shall be

prescribed by law." This legislative oversight clearly applies to all of the Board's powers

and duties, including the supervision of instruction. Additionally, Petitioners' argument

fails even if supervision of instruction is not under the controlling influence of the



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Legislature. HB 3399 does not address oversight of teaching, so supervision of

instruction is not clearly and plainly within the express prohibitions and limitations fixed

by the constitution, as discussed in Tate v. Logan,1961 OK 136, 19, 362 P.2d 670, __.

Petitioners present no plain and clear conflict with the Constitution. Their

questions must be answered, "No."

The function of the Court is limited to the determination of the validity or

invalidity of HB 3399. There is a presumption HB 3399 is constitutional.

[I] If the language of the act is susceptible of a meaning that will remove

the objection to its validity, such interpretation should be adopted.

Dobbs v. Board of County Com'rs of Oklahoma County, 1953 OK 159, 0, 257 P.2d 802,

__. In particular, the interpretation of "supervision of instruction" by its common

meaning, "oversight of teaching," confirms that the power to make education policy is

properly reserved to the Legislature: There is no language in the Oklahoma Constitution

prohibiting the Legislature from approving, disapproving, or amending statewide

education policies of policies of the Oklahoma public schools. Petitioners have failed to

show that Section 4 of HB 3399 is unconstitutional.

V. ARGUMENT

I. The Oklahoma Legislature has Constitutional authority to codify HB 3399 as

law in Oklahoma.

Article V, Section 36 of the Oklahoma Constitution extends the "authority" of the

Oklahoma Legislature "to all rightful subjects of legislation," without "restriction,

limitation, or exclusion" imposed by "any specific grant of [Constitutional] authority

upon any subject whatsoever."

"In extending the power of the legislature to 'all rightful subjects oflegislation,' the Legislature of the State of Oklahoma is Constitutionally



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vested with the power and authority to pass legislation on any subject not

withheld by the Constitution of this State or the Federal Constitution.

Spearman v. Williams, 415 P.2d 597 (Okl. 1966); Dobbs v. Board ofCounty Commissioners of the Okl. County, 208 Okl. 514, 257 P.2d 802

(Okl. 1953); Wentz v. Thomas, 159 Okl. 124, 15 P.2d 65 (1932)."

State of Oklahoma ex rel. Oklahoma Tax Commission v. Tom Daxon, State Auditor and

Inspector, (OK Tax Comm.) 1980 OK 28, 3, 607 P.2d 683, 687.

The Constitutions do not grant specific power to the Legislature, instead, they

provide any restrictions on the power of the Legislature. Given those restrictions, the

legislature is empowered to pass such legislation as it deems beneficial to the public

weal, as discussed in State ex rel. Grand Jury of McCurtain County v. Pate, 572 P.2d 226

(Okl. 1977).

Article V, Section 46 of the Oklahoma Constitution prohibits the Legislature from

passing certain local and special laws. There is no prohibition on the passage of general

laws, such as HB 3399, which applies to all public schools and all public school students.

(Seenote 1 on page 2, herein).

Because neither the Oklahoma Constitution nor the Federal Constitution grants

any power to the Oklahoma Board of Education, HB 3399 presents a "subject not

withheld" by either Constitution.

Petitioners attempt to override the Constitution by erroneously expanding

"supervision of instruction" to include the development of subject matter standards.

Article XIII, Section 5 of the Oklahoma Constitution requires the Legislature to prescribe

the powers and duties of the Board of Education. The Legislature also has the

Constitutional authority to prescribe the members of the Board of Education and to



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"establish and maintain a system of free public schools. . . ." Okla. Const. art. XIII, 5

and 1, respectively.

In order to establish a system of free public schools, the Legislature was

empowered to prepare and adopt subject matter standards, and, while maintaining

Oklahoma's system of free public schools, the Legislature remains empowered to revise

and adopt subject matter standards. The Constitution does not divest the legislature of

that power.

The Legislature's authority is further demonstrated in Title 70 O.S. 2011, 11-

103-6 of the School Code, which requires the State Board of Education to "adopt

curricular standards for instruction of students in the public schools of this state. . . ."

Clearly, the Legislature has the authority to require the State Board of Education to

design and adopt subject matter standards. However, the Constitution does not require

the Legislature to completely abandon that authority.

This Court has stated,

"We do not look to the Constitution to determine whether the Legislature

is authorized to do an act but rather to see whether it is prohibited. . . ."

Tate v. Logan, 1961 OK 136, 19, 362 P.2d 670, __.

With regard to the Oklahoma Board of Education, the Legislature has authority to

pass any legislation that is not withheld by the Oklahoma Constitution for the Board of

Education. The absence, in the Oklahoma Constitution, of any grant of power to the

Board confirms the Legislature's authority to pass HB 3399 and requires this Court to

deny Petitioners' request.

II. HB 3399 does not allow the Legislature to infringe on the

Constitutional authority of the Board of Education.



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As stated previously, HB3399 does not allow the Legislature to do anything. It is

the Legislature's supreme power that allows the Legislature to prescribe all powers and

duties of the Board. Okla. Const. art. XIII, 5. HB 3399 allows the Board to function as

prescribed therein by the Legislature

III. HB 3399 does not give the Legislature excessive, controlling influence

over the executive power of the Board of Education.

Again, HB 3399 gives no power to the Legislature. The Legislature has all power

not withheld by the Constitution. What Petitioners describe as "excessive, controlling

influence over the executive power of the Board," is influence required by the

Constitution, which places the Board under the controlling influence of the Legislature.

Okla. Const., Art. XIII, 5. All powers and duties of the Board are to be prescribed by

the Legislature.

Petitioners erroneously discuss the "executive power of the Board," while

ignoring the fact that the Board exists as currently constituted, only "until otherwise

provided by law," which could be interpreted as, "until changed by the Legislature."

Okla. Const., Art. XIII, 5. In addition to the powers and duties of the Board, the

composition of the Board is also under the control of the legislature.

The Legislature's Constitutionally-provided power over the Board defeats a

separation of powers argument. Without a grant of power from the Legislature, the

Board has no power.

VI. SOVEREIGNTY

This is actually a case sounding in sovereignty. Petitioners challenge Paragraph 4

of HB 3399, but ask for revocation of the entire bill. Granting this request would grant to

the Board of Education powers not provided by the Constitution.



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Removal of the Legislature from the preparation and adoption of subject matter

standards would essentially set up the Board as a fourth branch of government, able to

exercise both legislative and executive functions and free from the limitations of checks

and balances. It would also jeopardize all of Title 70 in the Oklahoma Statutes and place

the Board of Education in a position not anticipated by the Constitution. Such a grant of

authority to the Board would also relinquish control of Oklahoma's Education Policy to

the Federal Government and unleash Common Core in Oklahoma Public Schools against

the will of the people, the Oklahoma Legislature and the Oklahoma Governor and in

violation of the Constitution of the State of Oklahoma, which does not allow the

delegation of standards-establishment duties to others, especially to anonymous,

unaccountable entities outside the state.

In finding HB 3399 unconstitutional, this Court would set up an inter-government

compact with other agencies, external to the state of Oklahoma, and allow those agencies

to overtake the powers of the Oklahoma Legislature.

VII. CONCLUSION

This case is not justiciable for lack of standing by Petitioners. Also, the questions

raised by Petitioners regarding Section 4 of HB 3399 do not impact the remaining

sections of the bill. If Section 4 should be found unconstitutional, then the remainder of

HB 3399 will remain unchallenged. Fent, 2007 OK 27, 10 and In re ODOT, 2002 OK

74, 27 - 31.

Additionally, the sections of HB 3399 that repeal Common Core must be upheld

to avoid the unlawful transfer of vast amounts of responsibility over Oklahoma public

education away from the Board, beyond the Legislature's power, and outside Oklahoma..



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The Oklahoma Constitution, art. XIII, 1, 5, vests solely in the Oklahoma Legislature

the power to establish and maintain Oklahoma's system of public education. Clearly, this

power is intended to be exercised by the Legislature, itself, or as prescribed by the

Legislature. The Constitution authorizes no transfer of this power to the collective

control of many entities, including other states, the federal government and the private

interests that developed and own the Common Core standards.

Petitioners ask the Court to issue a writ that the State Department of Education is

prohibited from executing HB 3399. They do not ask for a finding that only Section 4 of

HB 3399 is unconstitutional. Clearly, Petitioners oppose HB 3399 in it entirety, but have

no legal challenge thereto. As shown herein, the answers to their questions must be

"No."

Perhaps most importantly, Petitioners have not shown without any possible doubt

that the Legislature erred in codifying HB 3399. Again,

If there is any doubt as to the Legislature's power to act in any given

situation, the doubt should be resolved in favor of the validity of the actiontaken by the Legislature. Restrictions and limitations upon legislativepower are to be construed strictly, and are not to be extended to include

matters not covered or implied by the language used. (Underline added.)

Tate v. Logan,1961 OK 136, 19, 362 P.2d 670, __.

Respectfully submitted,

____________________________________

Don M. Powers, OBA # 18810G. Kay Powers, OBA # 18811

-Of the Firm-

POWERS AT LAW,LLC

1420 Bond StreetEdmond, OK 73034



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(405) 359-5999

(405) 340 4474 (Facsimile)

ATTORNEYS FOR AMICUS CURIAE

ROPE (Restoring Oklahoma Public Education)

Jenni White, President

Documents

Pack v. State ROPE Amicus Brief Regarding Constitutionality of HB3399