Ramsdell v. North River School Dist. No. 200

In Ramsdell v. North River School Dist. No. 200, 104 Wn.2d 264, 704 P.2d 606, 608 (Wash.1985), the plaintiffs--parents requested a release for their children to attend a non-resident secondary school. The plaintiffs claimed that their residential school was inadequate, and that their children could be exposed to diverse viewpoints in the adjoining county's school. Id. The defendant--county board ("county board") denied the request, indicating that "'the board feels your case does not meet the state or local school guidelines for releases, nor can it be considered a hardship case.'" Id. The plaintiffs appealed, and the administrative law judge found that a more prestigious educational curriculum did not establish "special hardship or detrimental condition." Id. Again, the plaintiffs appealed, and the superintendent affirmed. Id. The plaintiffs sought judicial review, and the trial court reversed the superintendent's ruling, finding that even though the plaintiffs failed to establish "hardship," the plaintiffs' children should attend the schools which met their best educational interest. Id. at 609. The county board appealed, and the Washington Court of Appeals transferred the action to the Washington Supreme Court. Id. The plaintiffs averred that "there was a state granted constitutional right for their children to attend the non-resident school." The county board nevertheless contended that the resident school was a fully-certified school district, and that the plaintiffs failed to establish their prima facie case. Id. The Washington Supreme Court analyzed its statute, providing: School district boards of directors may, in receipt of reasonable compensation, make agreements with non-resident parents for their children to be released to the district's schools. If the school district boards deny this requested release, the parents must appeal to the Superintendent . . . .Id. at 610. The Court indicated that "without concrete evidence of inadequateness, special need or unique circumstances, we decline to rule that disparity among school districts entitles parents to transfer their children into different school districts." Id. at 611. Accordingly, the Court determined that the trial court erred in its ruling, and reinstated the superintendent's decision. Id.