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Lynch v. Commissioner of Educ., 317 Mass. 73, 56 N.E.2d 896

Facts

The plaintiffs, residents of Boston, filed a bill in equity against Julius E. Warren, the Commissioner of Education, and others, to prevent them from charging tuition and fees for books and supplies at the Framingham teachers college. Marie Lynch, a minor, was informed that she would need to pay an annual fee of $75 and approximately $35 for books and supplies to continue her education. The history of tuition fees at state teachers colleges was outlined, showing that fees had been gradually introduced since 1925, and the plaintiffs made no payments pending the outcome of the suit.

The material facts are these: There are nine teachers colleges established and maintained by the Commonwealth and among them is one located at Framingham which was established in 1839 as a normal school.

Issue

The main legal issue was whether the Commonwealth is constitutionally required to provide free education at state teachers colleges and whether the legislature could impose tuition fees.

The plaintiffs, however, contend that if the Legislature has the power to establish fees for tuition in State teachers colleges it has not done so, and that if it has such power it may not delegate it to the department of education and in any event has not attempted to do so.

Rule

The court ruled that the Constitution of the Commonwealth does not mandate free education at higher institutions, including teachers colleges, and that the legislature has the authority to establish tuition fees.

There is nothing in the contention of the plaintiffs that the Constitution of the Commonwealth provides for free education not only in common schools but also in higher institutions of learning such as teachers colleges.

Analysis

The court analyzed the legislative history and constitutional provisions regarding education, concluding that the legislature intended to allow the department of education to set reasonable tuition fees for residents of the Commonwealth. The court noted that the absence of a specific prohibition against tuition fees in the statute indicated legislative intent to permit such charges.

The court analyzed the legislative history and constitutional provisions regarding education, concluding that the legislature intended to allow the department of education to set reasonable tuition fees for residents of the Commonwealth.

Conclusion

The Supreme Judicial Court reversed the order for final decree and dismissed the plaintiffs' bill, affirming that the imposition of tuition fees was lawful.

The order for final decree entered in the court below is reversed and a final decree is to be entered dismissing the bill.

Who won?

The defendants prevailed in the case because the court found that the imposition of tuition fees was within the legislative authority and not in violation of the Constitution.

The defendants prevailed in the case because the court found that the imposition of tuition fees was within the legislative authority and not in violation of the Constitution.

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