Springfield Township, Franklin County v. Quick

Facts of the Case

At issue in Quick was a township's having sold its 16th section in 1836. Officials in the township took the sum of $7,423.36 that they received for the property, invested the money, and applied the interest to support the schools. Part of the argument in the litigation was whether the township was entitled to this money as well as to additional resources from a fund that accrued under the laws of the state of Indiana.

When Indiana adopted a new constitution in 1851, its eighth article established a school fund, derived from several sources, that was to be consolidated [Page 779]into a single fund. The first of these sources was the congressional township fund and any land still belonging to it. Ten other sources of funds were listed from which revenue was derived, and all of them were united into a common fund. The common fund was to be distributed among the counties according to the number of students that they had, with each county receiving an equal amount for each student, regardless of what officials provided for the students from their respective congressional townships funds. However, there was another section within article eight that specified that all of the trust funds that the state had were to be applied exclusively to the purposes for which each fund was created. In light of this provision, a suit in 1854 tested the validity of the new constitution.

The Supreme Court of Indiana ruled that selected funding provisions in the new constitution were null and void. Subsequently, when, in 1855 the Indiana legislature passed yet another new law providing for the distribution of the common fund, it inserted a provision that would not allow any township's congressional township fund to be diminished because of the distribution or to be diverted to any other township.

Officials in Springfield township filed suit, claiming that the township was entitled to both the interest from its own congressional township fund and to its distributive share of the common fund. The Supreme Court of Indiana decided against the Springfield township claim, because, according to the new law about the distribution, when a county disbursed funds to townships, officials were required to distribute the amounts given to each township equally, based on the number of students who resided there. At the same time, officials were supposed to take into consideration the amount of money that townships derived from their congressional funds, although county treasurers could not diminish the congressional funds or divert them to any other townships. The result was that in systems where the congressional fund was insufficient to cover expenditures for all students, the state would allocate funds to townships on the basis of need.

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