Harrisburg School District v. Hickok

COLINS, Judge,

concurring and dissenting.

I concur in the majority’s dismissal of Counts II through V, VII, and IX through XI of the School District’s complaint. I would also dismiss Counts I, VI, and VIII; therefore, I dissent to the majority opinion insofar as it denies the Commonwealth’s preliminary objections to those counts.

I disagree with the majority’s conclusion that Act 16 constitutes special legislation in violation Article III, Section 32 of the Pennsylvania Constitution. Act 16 is not legislation for a particular locality or for a private purpose; rather, it was written to address a problem that affects school districts statewide and it applies to all school districts. One small part of Act 16, the Reed Amendment, creates a class of one, Harrisburg, the state capital, but the Commonwealth has stated rational reasons that justify the legislature’s special treatment of Harrisburg, and comparatively, the Harrisburg School District is among the most in need of the potential benefits of immediate application of Act 16. The Reed Amendment does not treat the education of Harrisburg school students as more “special” than that of other students in the Commonwealth; rather, it recognizes that Harrisburg school students already have a history of low test scores, and puts it on a fast track to real educational reform. Where the need is so great, the circumstances justify going beyond an advisory team and putting the empowerment framework into the hands of *419a proven leader, Harrisburg Mayor Stephen Reed.

Similarly, equal protection principles do not prohibit the Commonwealth from classifying school districts for the purpose of receiving different treatment and do not require equal treatment of school districts having different needs. Defazio v. Civil Service Commission, 562 Pa. 431, 436-438, 756 A.2d 1103, 1106 (2000) (quoting Curtis v. Kline, 542 Pa. 249, 253-257, 666 A.2d 265, 267-68 (1995)). As I have stated, I believe that Act 16’s classification of Harrisburg for special treatment under the Reed Amendment was a reasonable classification, and the classification has a fair and substantial relationship to the object of the legislation; i.e., local education empowerment with an eye to reform and increasing students’ test scores.

In Act 16, the General Assembly has addressed the threat to the Commonwealth posed by low student test scores. Within that framework, the Reed Amendment acknowledges that the threat has become a longstanding reality in the Harrisburg School District, and the legislature made it possible for local officials to take the necessary steps to address the problem with dispatch. For these reasons, I would dismiss the School District’s complaint in its entirety.