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MENDOZA PLAINTIFFS’ OBJECTION TO TUSD REQUEST FOR APPROVAL OF SCHOOL CLOSURES
Maria Mendoza, et al.,Plaintiffs,United States of America,Plaintiff-Intervenor,v.Tucson United School District No. One, et al.,Defendants.Case No. CV 74-204 TUC DCBIntroductionTUSD seeks to eliminate a $17 million budget gap with a plan to close elevenschools that will result in savings of $4-5 million dollars. However, TUSD fails to explainhow it intends to meet the remaining shortfall of $12-13 million dollars. The Districtrushes to close schools causing disruption to thousands of students
without a plan forclosing the entire deficit and without adequately considering the impact of the closures onits constitutionally imposed mandate to increase integration in the District.The District has failed to use the Master Plan and school closure “process” tomeaningfully advance integration by utilizing the strategies provided in the joint UnitaryStatus Plan
including magnet schools, shaping of attendance boundaries, feeder patterns,clustering, open enrollment and the location of certain educational programs such as duallanguage programs. The “process” the District utilized for deciding which schools to closewas flawed as it neglected to consider these critical factors. The District should not beallowed to proceed with its school closure plan until it effectively utilizes the strategiesincorporated in the USP for achieving integration.
According to the District, “approximately 14, 768 students will be directly affected byschool closures.” TUSD Notice and Request for Approval of School Closures, Docket No.1419, filed 1/2/13 (“Notice and Request for Approval”), Exhibit I at 2.
Joint Proposed Unitary Status Plan Noting Areas of Party Disagreement (“ProposedUSP”), Docket No. 1411, filed 12/10/12.
Case 4:74-cv-00090-DCB Document 1423 Filed 01/22/13 Page 2 of 19