LAWSUIT SUMMARY

On February 14, 2017, Chicago Public Schools (CPS) and five parents of CPS students
filed a two-count Verified Complaint for Declaratory Judgment, Injunction and Other Relief
(Complaint) in the Circuit Court of Cook County seeking to end the State of Illinois
discriminatory education funding scheme. Plaintiffs bring their claims under the Illinois Civil
Rights Act of 2003, 740 ILCS 23/1 et seq., which prohibits the State from utilizing criteria or
methods of administration that have the effect of subjecting individuals to discrimination because
of their race, color, [or] national origin.

The lawsuits defendants are responsible for perpetuating and/or administering the States
unlawful education funding, and include Governor Bruce Rauner, the Illinois State Board of
Education (ISBE), ISBE Chairman Reverend James Meeks, ISBE Superintendent Dr. Tony
Smith and Comptroller Susana Mendoza.

Background

On May 17, 1954, the United States Supreme Court decided the landmark case Brown v.
Board of Education, 347 U.S. 483 (1954). Facing the realities then present in American public
education, the Supreme Court concluded in the field of public education, the doctrine of
separate but equal has no place. Id. at 495. Although Browns historic holding is rightly
celebrated, more than 60 years later, the reality is that a childs race continues to dictate whether
she or he will receive a good education or something far short.

Chicagos predominantly African American and Hispanic children still suffer from stark
educational inequalities. The State of Illinois maintains two separate and demonstrably unequal
systems for funding public education in the State: one for the City of Chicago, whose public
school children are 90% children of color, and the other for the rest of the State, whose public
school children are predominantly white.

Thirty-eight percent (38%) of CPS students are African American, 47% are Hispanic, and
6% are other students of color (for a total of approximately 90% children of color), and only 10%
are white. In contrast, for Illinois children attending public schools other than CPS, 58% are
white, only 12% are African American, 21% are Hispanic, and 9% are other students of color.
Among public school students in Illinois, an African American child is 11 times more likely than
a white child to attend CPS, and a Hispanic child is 9 times more likely than a white child to
attend CPS.
Count I -- Disparate Funding

In Fiscal Year 2016, the State spent 74 cents to educate Chicagos children for every
dollar the State spent to educate the predominantly white children outside Chicago. Combining
all sources of funding from the State, in Fiscal Year 2016, the State spent $1,604,828,661 on
CPS. The State spent $9,012,574,633 on all other school districts. CPS, therefore, received just
15% of the States $10,617,403,294 in education funding, despite having nearly 20% of the
students, according to Fiscal Year 2016 Illinois State Board of Education (ISBE) enrollment
records.

Unless enjoined by this Court, the disparity will continue. In Fiscal Year 2017, the State
is projected to spend $9,571,937,253 in total on other districts, and $1,734,345,898 in total on
CPS. As a result, CPS again will receive just 15% of the States $11,306,283,151 in education
funding, despite having nearly 20% of the students. And the States discriminatory funding is
expected to get even worse.

Count II -- Disparate Pension Funding Requirements

Illinois also imposes a separate and demonstrably unequal pension funding obligation on
CPS. The State assumes the primary responsibility for funding pensions on behalf of every
school district in Illinois except CPS. For example, in Fiscal Year 2017, Illinois statutory
funding obligation requires CPS to spend $1,891 per student on Chicago pensions. Over the
same period, non-Chicago school districts spend only $86 per student on pensions.

In Fiscal Year 2017, CPS statutory funding obligation to the Chicago Teachers Pension
Fund amounts to approximately 35% of CPS total teacher payroll. By contrast, in Fiscal Year
2017, non-CPS school districts will contribute only 1.5% of total teacher payroll to the Teachers
Retirement System.

Relief Sought

Plaintiffs are not asking the Court to dictate how the State should distribute its
educational funds or asking the Court to reduce teachers pension benefits. Rather, Plaintiffs ask
the Court to declare unlawful the States separate and unequal systems of funding public
education in Illinois and to enjoin Defendants from perpetuating a system that discriminates
against Plaintiffs.