
    WILLIAM PENN SCHOOL DISTRICT; Panther Valley School District; The School District of Lancaster; Greater Johnstown School District; Wilkes-Barre Area School District; Shenandoah Valley School District; Jamella and Bryant Miller, Parents of K.M., a Minor; Sheila Armstrong, Parent of S.A., Minor; Tyesha Strickland, Parent of E.T., Minor; Angel Martinez, Parent of A.M., Minor; Barbara Nemeth, Parent of C.M., Minor; Tracey Hughes, Parent of P.M.H., Minor; Pennsylvania Association of Rural and Small Schools; and The National Association for the Advancement of Colored People—Pennsylvania State Conference, Appellants v. PENNSYLVANIA DEPARTMENT OF EDUCATION; Joseph B. Scarnati III, in his Official Capacity as President Pro-Tempore of the Pennsylvania Senate; Michael C. Turzai, in his Official Capacity as the Speaker of the Pennsylvania House of Representatives; Tom Wolf in His Official Capacity as the Governor of the Commonwealth of Pennsylvania; Pennsylvania State Board of Education; and Pedro A. Rivera, in his Official Capacity as the Secretary of Education, Appellees
    No. 46 MAP 2015
    Supreme Court of Pennsylvania.
    ARGUED: September 13, 2016
    DECIDED: September 28, 2017
    
      Michael Churchill, Esq., Daniel Urevick-Ackelsberg, Esq., Public Interest Law Center of Philadelphia, Deborah Gordon Klehr, Esq., Cheryl Kleiman, Esq., Maura Mclnerney, Esq., Education Law Center, Matthew Jared Sheehan, Esq., O’Melveny & Myers, LLP, Brad M. Elias, Esq., Apar-na B. Joshi, Esq., for Appellants.
    Daniel Thomas Brier, Esq., Myers, Brier & Kelly, L.L.P., Lucy Elizabeth Fritz, Esq., John G. Knorr III, Esq., Pennsylvania Office of Attorney General, Lawrence G. McMichael, Esq., Patrick Michael Northen, Esq., Catherine Glenn Pappas, Esq., Dilworth Paxson, L.L.P., Gregory George Schwab, Esq., Robert M. Tomaine Jr., Esq., Pennsylvania Department of Education, for Appellees.
    Daniel Johnson Auerbach, Esq., City of Philadelphia Law Department, Ira Metr Karoll, Esq., Jones Day, Fred T. Magaziner, Esq., Dechert LLP, Ralph J. Teti, Esq., Willig, Williams & Davidson, Seth F. Kreimer, Esq., for Amicus parties.
    SAYLOR, C.J., BAER, TODD, DONOHUE, DOUGHERTY, WECHT, MUNDY, JJ.
   OPINION

JUSTICE WECHT

Appellant-Petitioners in this case are school district^, individuals, and groups with an interest in the quality of public education in Pennsylvania. They contend that the General Assembly and other Respondents collectively have failed to live up to the mandate, embodied in our Constitution’s Education Clause, that the General Assembly “provide for the maintenance and support of a thorough and efficient system of public education.” They further allege that the hybrid state-local approach to school financing results in untenable funding and resource disparities between wealthier and poorer school districts. They claim that the General Assembly’s failure legislatively to ameliorate those disparities to a greater extent than it does constitutes a violation of the equal protection of law guaranteed by the Pennsylvania Constitution.

The Commonwealth Court, sitting in its original jurisdiction, dismissed both claims at the pleading stage, relying upon this Court’s prior dispositions of similar cases. Arguably, these prior decisions held that such challenges to prerogatives constitutionally conferred upon the General Assembly were political questions that the courts cannot adjudicate without infringing upon the constitutional separation of powers. Concluding that these decisions controlled the issues presented, the Commonwealth Court ruled that Petitioners’ claims lay outside the reach of the judiciary as non-justiciable political questions pursuant to the principles set forth in Baker v. Carr, 369 U.S. 186, 82 S.Ct. 691, 7 L.Ed.2d 663 (1962), and its federal and Pennsylvania progeny.

It is settled beyond peradventure that constitutional promises must be kept. Since Marbury v. Madison, 5 U.S. 137, 1 Cranch 137, 2 L.Ed. 60 (1803), it has been well-established that the separation of powers in our tripartite system of government typically depends upon judicial review to check, acts or omissions by the other branches in derogation of constitutional requirements. That same separation sometimes demands that courts leave matters exclusively to the political branches. Nonetheless, “[t]he idea that any legislature ... can conclusively determine for the people and for the courts that what’ it enacts in the form of law, or what it authorizes its agents to do, is consistent with the fundamental law, is in opposition to the theory of our institutions.” Smyth v. Ames, 169 U.S. 466, 527, 18 S.Ct. 418, 42 L.Ed. 819 (1898). Thus, we must be skeptical of calls to abstain from a given constitutional dispute.- We hold that this is not a case that requires such abstention. Accordingly, we reverse the Commonwealth Court’s contrary ruling.

I. Background

A. The Pennsylvania Constitution and Public Education

The lineage of charters that led to Pennsylvania’s current Constitution offers a window into the shifting priorities and prerogatives animating the Commonwealth’s sometimes fractious history. This history informed the introduction and evolution of what became the Education Clause, a provision that has remained in our Constitution in materially the same form since 1874. We choose as a starting point William Penn’s 1682 Frame of Government of Pennsylvania. This was Pennsylvania’s first charter, .“in effect a constitution agreed,upon between Penn and the colonists,’’.and “the first real [Constitution followed in • the colony of Pennsylvania.” Gedid, supra n.6, § 3.2[a] at 33 (citing Thomas Raeburn White, Commentaries on the Constitution of Pennsylvania xvii (1907)). Notably, Penn’s Framework provided for the creation of schools, and the colonial assembly passed education legislation as early as 1683. William Penn himself stressed that the people should “spare no cost” in providing for education, opining that, “by such parsimony all is lost that is saved.” PARSS at 87 (quoting. .Philip S. Klein, et al, A History op Pennsylvania 384 (2d ed. 1973)). The Framework was short-lived, as Penn issued the Charter of Privileges in 1701, notable for its addition of certain defined individual liberties, and in particular its expansion 'of religious freedom and concomitant broadening of the electoral franchise, which, in turn, transformed Pennsylvania into a haven for oppressed religious sects. Notably absent from the Charter, though, was any provision concerning education.

Continued economic growth, as well as demographic, economic, and political changes, led to the Pennsylvania Convention of 1776. The Constitution that emerged from the convention, which came to be a model for other state charters, added extensive and now-familiar procedural protections, intra-govemmental checks and balances, and a detailed declaration of rights, Education also returned in the 1776 Constitution’s mandate that “[a] school or schools shall be established in each county by the legislature, for the convenient instruction of youth, with such salaries to the masters paid by the public, as may enable them to instruct youth at low prices.” PA. Const, of 1776 § 44.

Aspects of the 1776 Constitution, including in particular its further expansion of the franchise, its unicameral legislature, its weak executive Council of Censors lacking veto power, and a judiciary characterized by the combination of democratic selection and the brevity of judges’ terms, provoked conflict among political factions. This led to gridlock, recrimination, and, in due time, the 1789 Pennsylvania constitutional convention, which culminated in the adoption of the 1790 Constitution. The new Constitution divided legislative power into two houses, replaced the Council of Censors with a unitary executive having .veto power, and extended life tenure on good behavior to judges who were appointed rather than elected. Like other state constitutions enacted in that era, it resembled in its broad strokes, and in- its conception of tripartite representative democracy,.the United States Constitution..

The fledgling federal constitution conspicuously omitted- any mention of education, which presumably was among the unenumerated powers reserved to the states by the Tenth Amendment. But in Pennsylvania, the Constitution of 1790 preserved generally the' 1776 Constitution’s educational mandate, refining the language of the earlier clause to direct .the legislature “to provide, by law, for the establishment of schools throughout the: State, in such manner that the poor may be taught gratis.” PA. Const. , OF 1790 art. VII, § 1.

Judge Dan Pellegrini has provided a useful account of how the 1790 Education Clause’s mandate was applied in the decades that followed:

Laws effectuating the [1790 Education Clause], passed in 1802’, 1804[,] and 1809, allowed parents who declared themselves paupers to receive state aid to pay tuition at private institutions. But the “pauper school” approach reached few children, and as late as 1828, the state had paid the tuition of only 4,477 children that year. Ellwood P. Cubber-ley, Public Education in the United States 192 (2d ed. 1934). Over half the state’s 400,000 children were not enrolled in school. Stuart G. Noble, A History of American Education 160 (1938). The cause of universal public education gained wide support during the 1820s. The Pennsylvania Society for the Promotion of Public Schools, founded in 1827, petitioned for a revision of the state’s school laws. None of the governors during the period that the 1809 law was in effect believed that the constitutional mandate was being fulfilled. In his 1823 inaugural address to the state legislature, Governor [John] Schulze stated:
The object of the convention seems to have been, to diffuse the means of rudimental education so extensively, that they should be completely within the reach of all — the poor who could not pay for them, as well as the rich who could. Convinced that even liberty without knowledge, is but a precarious blessing, I cannot therefore too strongly recommend this subject to your consideration.
Journal of the Thirty-fourth House of Representatives, 1823-24 151-52, quoted in Lawrence A. Cremin, The American Common School 104 (1951) (hereinafter “American Common School”). George Wolf, another advocate of public education, was elected to two successive terms as governor, beginning in 1829. In his message to the legislature in 1830, Governor Wolf forcefully stated:
Of the various projects which present themselves, as tending to contribute most essentially to the welfare and happiness of a people, and which come within the scope of legislative action, and require legislative aid, there is none which gives more ample promise of success, than that of a liberal and enlightened system of education, by means of which, the light of knowledge will be diffused throughout the whole community, and imparted to every individual susceptible of partaking of its blessings; to the poor as well as to the rich, so that all may be fitted to participate in, and to fulfil all the duties which each one owes to himself, to God, and to his country. The [C]on-stitution of Pennsylvania imperatively enjoins the establishment of such a system. Public opinion demands it. The state of public morals calls for it; and the security and stability of the invaluable privileges which we have inherited from our ancestors require our immediate attention to it.
VI Register of Pennsylvania 386 (1830), quoted in American Common School 104-105. In his 1831 message to the legislature, Governor Wolf said:
The improvement of the mind should be the first care of the American statesman, and the dissemination of learning and knowledge ought to form one of the principal objects of his ambition. Virtue and intelligence are the only appropriate pillars upon which a [republican Government can securely rest .... Under these impressions, no opportunity has been omitted earnestly to press upon the attention of the legislature, the indispensable necessity of establishing by law a general system of common school education
V Pennsylvania Archives, Fourth Series 962-64, quoted in Klein & Hoogenboom, A History of Pennsylvania [page citation omitted] (2d ed. 1973).
The efforts of the proponents of public education eventually produced results. In 1831, the Report of the House Committee on Education addressed the shortcomings of the pauper school laws:
[T]he unremitted attention of your committee has been directed to the labour of compiling the details of a system of common schools, in which eventually all the children of our [C]ommonwealth may at least be instructed in reading, and a knowledge of the English language, in writing, arithmetic and geography — subjecting them to such regulations as may best promote their future usefulness — securing competent and able teachers, and providing for their support ....
VII Register of Pennsylvania 386 (1830), quoted in American Common School 105. This report contributed to the passage of a bill creating a permanent school fund. During the 1833-34 session, Senator Samuel Breck was appointed chairman of a joint committee on education which produced a report stating the following:
A radical defect in our laws upon the subject of education, is that the public aid now given, and imperfectly given, is confined to the poor. Aware of this, your committee have taken care to exclude the word poor, from the bill which will accompany this report, meaning to make the system general, that is to say, to form an educational association between the rich, the comparatively rich, and the destitute. Let them all fare alike in primary schools; receive the same elementary instruction; imbibe the same republican spirit, and be animated by a feeling of perfect equality.
XIII Register of Pennsylvania 97 (1834), quoted in American Common SCHOOL 106. The bill accompanying the report was passed into law and created a system of public schools. The act created school districts in every ward, township and borough, which were given the choice of participating in the new system or continuing to operate under the 1809 mandate of providing only for the education of the poor. To participate in the disbursement of state funds, each district was required to raise by local effort an amount twice that to be received from the state.[]
While the new law was passed almost unanimously and received broad support among the New England settlers of the northern tier counties and the Scotch-Irish Presbyterians of the western counties, opponents rallied to repeal the law in the Senate and almost succeeded in the House. Three groups were allied in their opposition to public education: property owners who opposed the use of taxes to fund the system; religious groups like the [Quakers], the Lutherans and the Mennonites who supported their own parochial schools; and the German-speaking settlers of the east-central counties who were opposed to the English language requirements. Thaddeus Stevens, then a member of the House of Representatives, eloquently spoke in defense of the school act and the supporters of public education were able to prevent the repeal of the law.[]

PARSS at 88-92 (citations modified; footnotes omitted).

It was left to Governor Wolfs successor, Joseph Ritner, and the first Superintendent of Common Schools, Thomas H. Bur-rowes, to implement the newly-designed system that followed. By 1837, 742 of 987 districts were participating in the state system. The notion of the pauper .school had been marginalized, and most parts of the state accepted a tax-based system of public education for all young people.

In its contribution to and convergence with other state charters and the federal constitution, Pennsylvania’s 1790 Constitution reflected the animating principles of a burgeoning nation. Nonetheless, simmering conflicts among competing factions, in part reflecting the divergent interests of the Commonwealth’s far-flung eastern and western populations, led to a successful 1837 popular referendum calling for a constitutional convention. The resulting 1838 Constitution adjusted the structure of government, providing refinements in the protection of rights and the imposition of additional limitations on legislative power. The 1790 Constitution’s Education Clause remained unchanged.

Judge Pellegrini continues:

-The 1850s saw an expansion of legislative activity • concerning education. In 1851, the Pennsylvania Supreme Court ruled that, the clause concerning free education for the poor, contained in the education provision of the constitutions of 1790 and 1838, was not a limitation on the power of the legislature]. Commonwealth v. Hartman, 17 Pa. 118 (1851). The [Cjourt held that the clause defined the minimum legislative effort and did not enjoin the legislature from doing more. Id, In 1852, another staunch supporter of public education, William Bigler, was elected governor. ... Governor Bigler oversaw an expansion of state efforts in education, which included the establishment of the first state normal schools and the State Teachers’ Association and the first publication of the •Pennsylvania School Journal.
During this period, Pennsylvania was not alone in its efforts to institute a universal system of public education. People like Horace Mann in Massachusetts, Henry Barnard in Connecticut, Samuel 'Lewis in Ohio, and John Pierce in Michigan led movements advocating publicly-funded universal education. Some states added education clauses to their constitutions or strengthened their commitment to education by passing new legislation. The phrase “thorough and efficient” was first included in the Education Clause of the Ohio Constitution of 1851 and over the next several decades-was added to the Constitutions of Minnesota, Maryland, New Jersey, Pennsylvania and West Virginia. ... [] The phrase can be traced to a lecture Mann delivered in 1840: “[T]he efficient and thorough education of the young was not merely commended to us, as a means of promoting private and public welfare, but commanded as the only safeguard against such a variety and extent of calamities as. no nation on earth has ever suffered.” Horace Mann, Lectures on Education, II Life & Works of Horace Mann 191 (1891),

PARSS at 93-94 (citations modified; footnotes omitted).

Pennsylvania did not revisit the Education Clause until the 1873 constitutional convention, when the drafters eliminated the prior clause’s focus upon instruction for the poor. The new clause directed the General Assembly to “provide for the maintenance and support of a thorough and efficient system of public schools, wherein all the children of this Commonwealth above the age of six years may be educated,” and specified that the legislature “shall appropriate at least one million dollars each year for that purpose.” PA. Const, of 1874 art. X, § 1. While the 1776, 1790, and 1838 Constitutions recognized education’s “vitally important part in our existence,” it was only upon the adoption of the 1874 Constitution that Pennsylvania “fortified” the public school system, making schools “an integral part of our governmental system, as a state institution,”, and rendering school districts “but agencies of the state Legislature to administer [its ■newly-defined] constitutional duty.” Wilson v. Sch. Dist. of Phila., 328 Pa. 225, 195 A. 90, 94-95 (1937); see Bd. of Pub. Educ. of First Sch. Dist. v. Ransley, 209 Pa. 51, 58 A. 122, 123 (1904) (“A review of constitutional provisions and legislative enactments clearly shows that the state hds regarded the education of its children as one of its duties and functions .... ”),

While the procedural posture of this case militates against delving deeply into the history of — or drawing broad conclusions regarding the collectivé intent underlying — the phrase “thorough and efficient,” some contemporaneous context nonetheless is illuminating. Most notably, delegates to the convention appear to have linked the importance of public education to the success of democracy, with William Darlington averring that “the perpetuity of free institutions rests, in a large degree, upon the intelligence of the people, and that intelligence is to be secured by education,” and further opining that “[t]he section on education is second in importance to no other section to be submitted to this Convention.” PARSS at 98 (quoting II Pennsylvania Debates of 1873 421). This Court, in turn, has noted that the General Assembly, while enacting piecemeal legislation in its service, did not entirely fulfill the 1790 Constitution’s education mandate until the Act of May 8, 1854, P.L. 617, which for the first time “established a system of common school education for all the counties of the [C]om-monwealth.” Ransley, 58 A. at 123.

Reflecting a general preference for the protection of local school district prerogatives over state control that persists to this day in Pennsylvania and throughout the country, the Convention rejected a proposal to add the word “uniform” in the Education Clause ahead of the words “thorough” and “efficient.” Opponents of uniformity expressed, inter alia, concerns that the word would deny schools the ability to tailor their instruction to the disparate needs of children in urban and rural districts, with one conventioneer cautioning against the imposition of statewide curricular requirements. Concerns also arose that local districts would be precluded from raising additional funds to supplement and enrich the educations they might provide, a disfavored intrusion upon local prerogatives. See Danson v. Casey, 484 Pa. 415, 399 A.2d 360, 366-67 (1979) (noting that the framers of the 1874 Constitution considered and rejected adding a uniformity requirement to the Education Clause, thereby “endors[ing] the concept of local control to meet diverse local needs”). The risk of a race to the bottom also was considered, based upon the fear that, far from elevating school districts with lower standards, a uniformity requirement would cause higher-flying schools to weaken their efforts.

A spirited debate also arose regarding the proposed $1 million funding mandate. Supporters argued that such funds would prevent the “farcical” situation where-under some local taxing jurisdictions, in order to finance a school year of state-specified duration, would be forced to impose an onerous millage rate upon their residents, while other districts would be able to impose a less burdensome funding structure on their own constituents. Instead, the appropriation “would equalize the burdens of supporting the system” of education prescribed by the Constitution. PARSS at 101 (quoting II PENNSYLVANIA DEBATES OF 1873 679). Conversely, opponents raised the specter of state intrusion upon local districts’ prerogatives to tailor education to local resources and needs.

The 1874 numbering and text of the Education Clause were amended during the 1967 constitutional convention to read, “The General Assembly shall provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.” PA. Const, art. Ill, § 14. Once again, uniformity was absent from the text. The $1 million appropriation ■ requirement was omitted as anachronistic. Thus, while the language upon which the instant case primarily hinges first appeared in our Constitution in 1874, it did not take on its present form until the adoption of the 1968 Constitution.

B. The Parties and the Action

Appellant-Petitioners include public school. districts spanning the Commonwealth, from Philadelphia and Delaware Counties in southeastern Pennsylvania to Cambria County in the west. Petitioners also include students and parents and guardians of students who attend the named school districts and others. They further include the Pennsylvania Association of Rural and Small Schools (“PARSS”), a statewide membership organization that comprises approximately 150 school districts and provides advocacy and training to address problems that affect rural school districts, and . the NAACP — Pennsylvania State Conference, a Commonwealth affiliate of the National Association for the Advancement of Colored People.

As set forth at length below, Petitioners filed a Petition for Review in the Commonwealth Court’s original jurisdiction, naming as Respondents the President Pro Tempore of the Pennsylvania Senate, Joseph B. Scarnati, III, and the then-Speaker of the Pennsylvania House of Representatives, Samuel H. Smith (collectively, “Legislative Respondents”); and the Pennsylvania Department of Education, S,ecre-tary of Education Pedro Rivera, and Governor Tom Wolf (collectively, “Executive Respondents”). Petitioners sought declaratory and injunctive relief aimed at rectifying what they alleged are constitutional deficiencies in Pennsylvania’s system of public education arising from the General Assembly’s failure to support and maintain the thorough and efficient system of education mandated by the Pennsylvania Constitution.

C. Petitioners’ Allegations

Petitioners’ averments, which for purposes of review wé must take as true and read in the light most favorable to their causes of action, fall into two sometimes overlapping categories. Generally, Petitioners aver that Pennsylvania’s school funding system is flawed on its face in its failure to ensure, in tandem with local funding, that each school district has the resources necessary to provide an adequate education. This includes broad averments as well as more particularized allegations, couched in quantitative comparisons of various districts’ resources and respective capacities to provide an education of a quality that satisfies the Education Clause’s mandate. Specifically, Petitioners plead numerous allegations concerning the circumstances faced by their own districts, as well as the alleged injuries that a constitutionally inadequate school system has caused the individual petitioners, children attending such schools and their parents or guardians. As an organizing principle, we review these allegations in turn.

In 1999, the General Assembly imposed an elaborate set of standards to govern the content of educational materials, which led to the adoption of assessment and accountability measures tied to those standards. Thus, through authority conferred by the School Code, the Department of Education adopted a series of regulations “to establish rigorous academic standards and assessments, applicable only to the public schools in this Commonwealth, to facilitate the improvement of student achievement and to provide parents and communities a measure by. which school performance can be determined.” 22 Pa. Code § 4.2.

In its statement of “general policies,” the new regulatory framework reinforced the principle that districts should be free to fashion'local curricula to achieve prescribed academic standards, retaining “the greatest possible flexibility in curriculum planning,” while meeting prescribed course and curriculum requirements, ensuring the provision of specified numbers of days and hours of instruction at different school levels, and maintaining a sufficient professional staff. The Department further committed to support local efforts, by, e.g., establishing model curricula and diagnostic tools tailored to satisfying the state.assessment system. 22 Pa. Code. § 4.4. The state assessments are conducted primarily through the Pennsylvania System of School Assessment (“PSSA”) and Keystone Exams. See generally 22 Pa. Code. §§ 4.51 et seq.

In 2008, the General Assembly passed Act 61. In that measure, thq legislature responded to an extensive “costing out” study it had commissioned, which had established benchmarks for effective funding levels on a district-by-district basis and pointed to widespread funding deficiencies and' inequities in Pennsylvania’s public school system. The General Assembly implemented a “Basic Education Funding Plan” for calculating the distribution of state resources among Pennsylvania’s school districts. The costing-out study found that 94% of Pennsylvania school districts were spending less than should be spent to meet the Commonwealth’s own academic standards. The poorest quintile of school districts needed to spend 38% more than they were spending, while the wealthiest quintile needed to increase spending by 7%. The aggregate statewide shortfall relative to what was required to meet those standards was over $20 billion. Under Act 61, funding levels for the 2008-09 school year increased by $274.7'million, a 5% increase over the preceding year. In the two years that followed, utilizing the same formula, the Commonwealth increased state funding by approximately $300 million and $355 million, respectively. Thus, as against the study’s recommended $20 billion increase, Act 61 provided for an increase of roughly $1 billion over three school years.

The increased funding drew heavily upon federal stimulus funds furnished to the state pursuant to the American Recovery and Reinvestment Act of 2009 (“ARRA”). ARRA expired in .2011, by which time the Commonwealth had relied upon hundreds of millions of federal dollars to reduce the Commonwealth’s direct contribution to the funding pool by which Act 61’s mandate was fulfilled. In the wake of ARRA’s expiration, the Commonwealth faced a shortfall of over $800 million relative to prior funding levels, which was reflected in the 2011 budget. Pursuant thereto, the basic education subsidy was reduced by $420. million; Accountability Block Grants, which fund initiatives such as full-day kindergarten, tutoring assistance, and class size reduction, by $160 million; charter school reimbursements, which partially compensate school districts for the cost of transferring district funds to charter schools, by $224 million; and the Educational Assistance- Program, which funds tutoring services, by $47 million, with additional .reductions affecting other initiatives, including those aimed at improving educational achievement in low-performing schools. The 2011 budget also destabilized school funding generally, by abandoning Act 61’s long-term funding formula in favor of mutable annual funding calculations. Compounding the funding shortfalls was the Taxpayer Relief Act of 2006, which restricted the ability of local jurisdictions to offset state budget cuts by increasing local taxes. In 2011, Petitioners note, in the face of the above funding reductions, the Department of Education, pursuant to the Taxpayer Relief Act, set the relevant index at a low level such that, even given the political will, local districts simply lacked the authority to raise local taxes enough to offset fully the state funding reductions.

Petitioners allege that the 2011 cuts hit low-wealth districts much harder than more prosperous districts, reducing per capita expenditures by $833 in districts where more than half the students lived in low-income households in the 2011-12 school year, as compared to per capita reductions of approximately $166 in districts with student bodies comprised of 25% or fewer low-income students. Petition for Review (“Petition”) at 54 ¶ 142 & n.46 (citing Pa. Budget & Policy Gtr. Staff, Pa. House Budget Locks in Most of the School Funding Cuts, June 21, 2013). Petitioners further allege a host of pronounced inequities within and among school districts that obtained under the 2011 funding scheme, including but riot restricted to massive district-by-district funding' disparities; low-wealth districts’ inability to provide individualized instruction to children who require it; shortages of essential learning materials such as computers and text books; persistent and ongoing reductions in teachers and staff, with concomitant increases in student-teacher ratios and class size; the elimination of educational programs such as art, music, and foreign languages; and deficiencies in learning materials and physical school facilities.

Petitioners offered an overview of the funding scheme that applied when they filed their Petition. Their account is quite detailed, but for present purposes it suffices to highlight the broader points. Petitioners aver that 87% of Pennsylvania’s public education budget is funded through state appropriations and local property-taxes, while 13% is contributed by the federal government. In 2011, local taxes, provided approximately 53%, with state appropriations comprising approximately 34% of statewide public school expenditures. State funds are distributed according to an aid ratio, which divides state funding according to various formulas that are designed to account for the aggregate property values and personal incomes in a given school district in discerning, speaking broadly, the wealth per student in a given district. A district’s “wealth” is then measured against the state average, and the less favorably it compares, the greater proportional share of state education funds it receives.

Districts with lower wealth per student values are unable to raise the same per capita funding through local property taxes as districts with higher values. The dependence of local tax revenues on the application of millage rates, which can vary over only a limited range, upon the aggregate value of the property in the district confers an insuperable advantage to districts that have a ratio of assessed property wealth per student that is significantly higher than districts with less aggregate property value. Thus, even low-wealth districts that impose substantially higher tax rates on their property cannot generate close to as much tax revenue per student as districts with substantially higher property values, even when the latter districts impose tax rates that are a fraction of those imposed by low-wealth districts. Thus, while Shenandoah Valley School District applied a property tax rate of 26.8 equalized mills, its local tax collections were only $4,011.48 per student. Conversely, Lower Merion School District, at 14.7 equalized mills, collected over $23,000 per student. Tredyffrin / Easttown School District, which applied a millage rate substantially less than half that applied by Shenandoah Valley, collected $19,418.38 per student, well over four times Shenandoah Valley’s per-student revenue. Petitioners document numerous similar disparities between wealthy and low-wealth districts across the Commonwealth.

Turning to Petitioners’ more specific allegations, the School District of Lancaster has eliminated 100 teaching positions and more than twenty administrative positions, substantially increasing the student-teacher ratio throughout the' district. Where Lancaster once employed twenty librarians, it now employs five. In 2011 and 2012, Lancaster imposed a hiring and salary freeze for teachers and other staff. Panther Valley School District has struggled similarly since 2011. The number of elementary school and high school teachers has been reduced by 10%. All district librarian positions were eliminated, as were all elementary school technology coach positions. Reductions also have adversely affected Panther Valley’s ability to support its growing population of English language-learning students. Greater Johns-town School District, where an unusually high proportion of students have incarcerated, substance-abusing, and/or mentally ill family members, also has labored under the burden of reduced funding. It has eliminated twenty-five teacher positions, and has an insufficient number of administrators, counselors, and librarians, with two librarians serving fodr schools, resulting in cutbacks to its reading intervention program. The William 'Penn School District has eliminated fiftyseyen teachers, five administrators, and .twelve- support staff. None .of its schools employs a full-time guidance counselor, it has eliminated one librarian position, and in 2011 it eliminated all of its reading specialist positions. Due to severe staff reductions, William Penn’s former seven-period schedule has been reduced to six periods.

Petitioners further detail reductions in Petitioner School Districts of various educational programs, including art, physical education, and health education, which, Petitioners argue, are important to preparing students for “civic, economic, and social success.” Id. at 85-86 ¶204. Schools also have reduced or eliminated vocational pro: grams, interventions for struggling and at-risk students, English language-learning assistance, and programming for gifted students, including advanced placement courses. Lancaster has cut summer, tutoring programs to non-high school students and nearly all foreign language education. Only half of students have access to shop and computer classes. Panther Valley has made; similarly dramatic cuts, and also eliminated driver’s education. and SAT preparation. Greater Johnstown has been forced to reduce severely its intervention, remediation, and special education services. Similar reductions have been required in the Wilkes-Barre Area and William Penn School Districts. These cuts, they allege, have been forced primarily upon economically disadvantaged districts, while more prosperous districts have remained largely unscathed.

Petitioners also identify severe shortages in classroom materials and equip: ment, as well as deteriorating schools. In the School District of Lancaster, for example, Petitioners allege that much of the furniture is in need of repair or replacement, projectors are non-functioning,' and textbooks and computers are severely out of date.- The roof over Panther Valley’s overcrowded elementary school is in need of repair, and as a temporary measure to address a' shortage of -usable space, the district has placed children in twelve modular classrooms. In Greater Johnstown, the roof over the middle school’s auditorium is collapsing, plaster is falling from crumbling walls and ceilings,- and some bathrooms are in such disrepair that they cannot be used. Much of the technology in the Wilkes-Barre Area School District is ten or more years old, and that district’s physical facilities, too, are in poor condition, In the William Penn School District, textbooks are > so out of date that they do not match Pennsylvania state curricular requirements, -and high school students may not bring-some texts home — should they be lost, the school will not be able to replace them. In twenty-three of thirty-two school buildings in Philadelphia surveyed by Philadelphia in partnership with the Health and Welfare Fund and the federal Institute for Occupational Safety and Health, investigators found dampness, mold, or water damage in more than a third of the rooms.

By way of contrast, in the Lower Merion School District, all kindergartners and first-graders have access to iPads, and all high school freshmen are issued laptops to use as their own during their high school years.

Perhaps most importantly, Petitioners allege that certain programs and services that disadvantaged districts have been forced to reduce or eliminate are essential to equip students to meet the proficiency standards imposed by the General Assembly. Teacher layoffs and concomitant class size increases; reductions in advanced studies and programs such as art and music, as well as áfter-school and summer school programs for supplemental instruction; the elimination or reduction of teacher education and development relative to the areas tested; reductions in preschool and early childhood programs; out-of-date instructional materials; and the various other deficiencies enumerated above all work to prevent disadvantaged school districts from meeting the educational standards imposed by the state.

Based on the foregoing allegations, Petitioners’ Petition sets forth two counts. In Count I, Petitioners assert that Respondents have violated their collective constitutional duty under the Education Clause to “provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.” PA. Const, art. Ill, § 14. In this regard, they allege that Respondents have defined the content of an adequate education — ie., one that will “serve the needs of the Commonwealth” — by promulgating academic .standards assessed by the PSSA and Keystone exams. Petitioners aver that Respondents failed to provide the school districts in question with enough funding to ensure that all students have an opportunity to receive an adequate education — where funding is measured by the allocations suggested by the General Assembly-commissioned c'osting-out study, and adequacy is tested by whether the students are prepared to “meet state academic standards” and to achieve “civic, economic, and social success” beyond school. Id, at 118 ¶304. Petitioners maintain that the current levels and all’dcation of school funding “are irrational, arbitrary, and not reasonably calculated to ensure that all Pennsylvania schoolchildren have access to an adequate education.” Id. at 118 ¶ 305. Consequently, Petitioners claim, the General Assembly has failed to maintain and support “a thorough and efficient system of public education.”

In effect, .Petitioners posit that Pennsylvania law imposes a threshold obligation to provide all Pennsylvania students with an “adequate” education, which they define in part by reference to the very standards imposed by the General Assembly and the Department of Education, and in part by reference to the broader, goal, of enabling students to “participate meaningfully in the economic, civic, and social activities of our society." That is to say, while. Petitioners rely significantly upon the proposition that the very instantiation of elaborate goals and assessment tools by the General Assembly reflects a legislative effort to define an adequate education against which constitutional adequacy can be measured, they appeal distinctly to broader notions of what constitutes a constitutionally adequate education of a sort that is-thorough and efficient.

In their second count, Petitioners assert that Respondents have violated equal protection principles under Article III, Section 32 of the Pennsylvania Constitution. They aver that education is a fundamental right, triggering strict scrutiny of the disadvantageous classification reflected in the disparity of educational resources at the disposal of, low and high-wealth districts. Petitioners do not dispute that a constitutional school funding scheme would still enable wealthier districts to provide greater resources to their students than districts that cannot raise as much money through local taxes. But they maintain that the Constitution “imposes, a duty on the Commonwealth to ensure that all students have the same basic level of educational opportunity,” that is, “the same fundamental opportunity to meet academic standards and to, obtain an adequate education that prepares the student for civil, economic, and social success.” Id. at 119 ¶ 308. Petitioners contend that the state charter “prohibits the General Assembly from irrationally enacting laws that benefit a select few.” Id. at 119 ¶ 309. Petitioners assert that many funding methodologies exist that would support the state’s interest in preserving local control of public education without compromising the ability of students in low-wealth school districts to obtain an adequate education. By adopting a school funding program that discriminates against students living in such districts by denying them an equal opportunity to obtain an adequate education, the General Assembly, according to Petitioners, has denied the disadvantaged students equal protection. Id. at 119-20 ¶¶ 308-311.

In connection with both counts, Petitioners seek declaratory relief consistent with their allegations regarding Respondents’ respective obligations, and in particular concerning the scope of the General Assembly’s mandate under the Education Clause, as well as permanent injunctive relief directing Respondents to rectify the situation accordingly. Petitioners request that the Commonwealth Court retain jurisdiction in order to ensure Respondents’ compliance.

Legislative and Executive Respondents each filed preliminary objections in the nature of a demurrer. See Pa.R.C.P. 1028(a)(4). Respondents averred primarily that Petitioners’ claims present non-justiciable political questions. They maintained that responsibility for providing a thorough and efficient system of public education is textually conferred exclusively upon the legislature and that there are no judicially manageable standards for granting relief. They reasoned that these factors require courts to abstain pursuant to the political question doctrine under Baker, as adopted by this Court. Respondents also argued that Petitioners failed to state an equal protection claim upon which relief may be granted because .they do not have a fundamental right to education entitling them to strict scrutiny of the school funding scheme, and the existing statutory scheme rationally serves the state’s interest in maintaining and supporting a thorough and efficient system of public education. Finally, Respondents averred that Petitioners’ causes of action were barred by sovereign immunity — to the extent they sought mandatory injunctive relief — as well as the separation of powers doctrine insofar as Petitioners asked the judicial branch to compel action by the General Assembly and to subject it to ongoing judicial supervision.

D. The Commonwealth Court’s Decision

In a unanimous, published decision, the Commonwealth Court sustained Respondents’ preliminary objections and dismissed Petitioners’ Petition on the grounds that, pursuant to this Court’s precedent, both the Education Clause claims and the equal protection claim entail non-justicia-ble political questions. See William Penn Sch. Dist. v. Pa. Dep’t of Educ., 114 A.3d 456, 464 & n.15 (Pa. Cmwlth. 2015) (en banc).

Initially, the Commonwealth Court observed that this Court has relied upon the Baker consideration's to ascertain, whether the political question doctrine counsels in favor of abstention in a given case. See id. at 462 (citing Robinson Twp. v. Commonwealth, 623 Pa. 564, 83 A.3d 901, 928 (2013), and Sweeney v. Tucker, 473 Pa. 493, 375 A.2d 698 (1977)). Rather than analyze the Baker factors anew, however, the Commonwealth Court found that the question of justiciability was controlled by this Court’s decision in Marrero v. Commonwealth, 559 Pa. 14, 739 A.2d 110 (1999) (“Marrero II"), which relied primarily upon Danson v. Casey, 484 Pa. 415, 399 A.2d 360 (1979). As read by the Commonwealth Court, in Marrero II, this Court held that the Education Clause did not confer upon students ah individual right to an education of any particular quality. Rather, it imposed an exclusive mandate upon the General Assembly to provide for the aforesaid maintenance and support of a thorough and efficient system of public education. The Court further maintained that the Education Clause precluded the General Assembly from establishing any educational policy that future legislatures cannot change. “[T]he very essence’’ of the Education Clause, it held, “is to enable successive legislatures to adopt a changing program to keep abreast of educational advances.” William Penn Sch. Dist., 114 A.3d at 462 (quoting Marrero II, 739 A.2d at 112). Consequently, it would be equally violative of the Education Clause’s “essence” for the Court to establish any fixed standard by which to measure thoroughness and efficiency. The Marrero II Court thus concluded that “the only judicially manageable standard this [Cjourt could adopt would be the rigid rule that each pupil must receive the same dollar expenditures,” and, because expenditures per pupil “are not the exclusive yardstick of educational quality, or even constitutional quantity,” such a standard would offend the historical means and intended ends of the Education Clause. William Penn Sch. Dist., 114 A.3d at 463 (quoting Marrero II, 739 A.2d at 113). Thus, any legislative scheme with “a reasonable relation” to providing “for . the maintenance and support of a thorough and efficient system of public schools” passes constitutional muster. Id. (quoting Marrero II, 739 A.2d at 113).

The Commonwealth Court rejected Petitioners’ attempt to distinguish Damon and Marrero II on the basis that subsequently-adopted education standards and assessments, viewed in tandem with the findings of the legislatively-commissioned costing-out study, have revealed a judicially discoverable and manageable standard by which to measure constitutional adequacy. Such considerations, the Commonwealth Court held, might establish salutary policy-related benchmarks, but they cannot supply a judicially manageable standard enabling a court to determine whether the Legislature has fulfilled its constitutional duties without overstepping its bounds. See id. Thus, as in Marrero II, that want of judicially manageable standards rendered Petitioners’ claims non-justiciable.

This appeal followed. This Court has exclusive jurisdiction over Petitioners’ appeal. See 42 Pa.C.S- § 723(a) (“The Supreme Court shall have exclusive jurisdiction of appeals from final orders of the Commonwealth Court entered in any matter which was originally commenced in the Commonwealth Court.”).

II. Issues Presented and Standards of Review

Petitioners frame 'their issues for review as follows:

A. Education Clause Claims
Where a petition alleges that the legislature’s school[-]funding scheme bears no relationship to the actual cost of preparing students to meet state academic standards, does the political jquestion doctrine bar the judiciary from considering whether the legislature has complied with its constitutional duty to support a thorough and efficient system of public education?
B. Equal Protection
Where a petition alleges gross and irrational disparities in school funding between low-wealth and high-wealth school districts, does the political question doctrine preclude students in low-wealth school districts from asserting an equal protection claim to protect their individual constitutional rights?

Brief for Petitioners at 2.

We exercise de novo review of a lower tribunal’s order sustaining preliminary objections in the nature of a demurrer. Bruno v. Erie Ins. Co., 630 Pa. 79, 106 A.3d 48, 56 (2014). The scope of our review is plenary. Kuren v. Luzerne Cnty., 146 A.3d 715, 753 (Pa. 2016). We must determine “whether, on the facts averred, the law says with certainty that no recovery is possible.” Bruno, 106 A.3d at 56. In conducting our review, “we accept as true all well-pleaded material facts set forth in the [petition for review] and all inferences fairly deducible from those facts.” Kuren, 146 A.3d at 718 n.1. We will sustain preliminary objections “only when, based on the facts pleaded, it is clear and free from doubt that the complainant will be unable to prove facts legally sufficient to establish a right to relief.” Id. (quoting Mazur v. Trinity Area Sch. Dist., 599 Pa. 232, 961 A.2d 96, 101 (2008)).

III. Discussion

A. Mootness and Appealability

As noted, supra n.25, with the enactment of 72 P.S. § 25-2502.53 and related provisions (hereinafter, “Act 35”) during the pendency of this appeal, the General Assembly supplanted the funding formula that applied when Petitioners filed suit. This new enactment is the subject of a Supplemental Brief submitted by Governor Tom Wolf, to which Petitioners responded in turn.. Governor Wolf submits that Act 35 for the first time bases allocations on the “objective needs of each district.” Supplemental Brief of Governor Tom Wolf at 3. Governor Wolf contends that these salutary changes militate in favor of affirmance, but does, not argue that the changes moot Petitioners’ claims. The question presented concerns the justiciability . of Petitioners’ claims. The nature of the applicable state formula (which can change any time the legislature chooses) goes to the correct ruling only if the claims are justiciable in the first instance. Changes in the formula do not render the questions presented moot, nor do they materially affect the substance of our ruling in the case’s present posture.

B, Justiciability and the Political Question Doctrine

The cornerstone of our republican democracy is the principle of government divided into three separate, co-equal branches that both empower and constrain one another. See Robinson Twp., 83 A.3d at 927 n.16. Judicial review stands as a bulwark against unconstitutional or otherwise illegal actions by the two political branches. “It is emphatically the province and duty of the judicial department,” instructed Chief Justice John Marshall, “to say what the law is.” Marbury v. Madison, 5 U.S. 137, 177, 1 Crunch 137, 2 L.Ed. 60 (1803). The foundation for the rule of law as we have come to know it is the axiom that, when disagreements arise, the Court has the final word regarding the Constitution’s meaning.

Even as the separation of powers upon which our system depends relies substantially upon judicial review, thé courts long have recognized that the very same imperatives sometimes require judicial abstention. In Marbury itself, the Court contemplated the prospect that certain legal acts and omissions may be neither assessed nor corrected by judicial intervention. Id. at 164 (“That there' may be such cases is not to be questioned .. 1. ”). As Chief Justice Marshall allowed, and as the centuries have proven, judicial review has its limitations, including those suggested by what has come to be known as the political question doctrine.

The parameters of the political question doctrine have never been amenable to precise definition. In 1956, Justice .Felix Frankfurter acknowledged the' difficulty that attends any effort to delineate the scope and application of the doctrine:

I ... believe that no judge charged with the duty of enforcing the Due Process Clauses of the Fifth and Fourteenth Amendments, and the Equal Protection of the Laws Clause of the Fourteenth Amendment, can free himself from the disquietude that the line is often Very thin between the cases in which the Court felt compelled to abstain from adjudication because of their “political” nature, and the cases that so frequently arise in applying the concepts of “liberty” and “equality.”

Felix Frankfurter, John Marshall and the Judicial Function, 69 Harv. L. Rev. 217, 227 (1955).

Not long after Justice Frankfurter expressed his misgivings, the United States Supreme Court, confronted with a challenge to state-level efforts to fashion congressional districts, distilled the following six-factor test from its prior political question decisions:

[Sjeveral formulations which vary slightly according to the settings in which the questions arise may describe a political question, although each has one or more elements which identify it as essentially a function of the separation of powers'. Prominent on the surface of any case held to involve a political 'question is found a textually demonstrable constitutional commitment of the issue to a coordinate political department; or a lack of judicially discoverable and manageable standards for resolving it; or the impossibility of deciding without an initial policy determination of a kind clearly for non-judicial discretion; or the impossibility of a court’s undertaking independent resolution without expressing lack of the respect due coordinate branches of government; or an unusual need for unquestioning . adherence to a political decision already made; or the potentiality of embarrassment from multifarious pronouncements by various departments on one question.

Baker, 369 U.S. at 217, 82 S.Ct. 691.

Baker has not appreciably mitigated the difficulty of locating Justice Frankfurter’s “very thin” line. The Baker Court itself acknowledged that its discussion “require[d] review of a number of political question cases, in order to expose the attributes of the doctrine — attributes which, in various settings, diverge, combine, appear, and disappear in seeming disorderliness.” Id. at 210, 82 S.Ct. 691. The Court also made the following observation:

Much confusion results from the capacity of the ‘political question’ label to obscure the need for case-by-case inquiry. Deciding whether a matter has in any measure been committed by the Constitution to another branch of government ... is itself a delicate exercise in constitutional interpretation, and is a responsibility of this Court as ultimate interpreter of the Constitution.

Id. at 210-11, 82 S.Ct. 691; accord Nixon v. United States, 506 U.S. 224, 228, 113 S.Ct. 732, 122 L.Ed.2d 1 (1993); Powell v. McCormack, 395 U.S. 486, 521, 89 S.Ct. 1944, 23 L.Ed.2d 491 (1969). “[Deference,” the Court said, “rests on reason, not habit.” Baker, 369 U.S. at 213, 82 S.Ct. 691.

Although Pennsylvania has employed the Baker factors in its own political question jurisprudence, we mine the doctrine from a different seam. We have held that, “[i]n contrast to the federal approach, notions of case or controversy and justiciability have no constitutional predicate, do not involve a court’s jurisdiction, and are regarded instead as prudential concerns implicating courts’ self-imposed limitations.” Robinson Twp., 83 A.3d at 917; see Zemprelli v. Daniels, 496 Pa. 247, 436 A.2d 1165, 1169 (1981) (quoting Laurence Tribe, American Constitutional Law 79 (1978)) (“Thus the political question doctrine, like other justiciability doctrines, at bottom reflects the mixture of constitutional interpretation and judicial discretion which is an inevitable by-product of the efforts of federal courts to define their own limitations.”); cf. Nixon, 506 U.S. at 252-53, 113 S.Ct. 732 (Souter, J., concurring) (“[T]he political question doctrine is essentially a function of the separation of powers, ... deriving in large part from prudential concerns about the respect [the judiciary] owes the political departments. Not all interference is inappropriate or disrespectful, however, and application of the doctrine ultimately turns, as Learned Hand put it, on ‘how importunately the occasion demands an answer.’ ” (citations and some internal quotation marks and modifications omitted)).

In Robinson Township, Chief Justice Castille synthesized our political question jurisprudence as follows:

The judicial power of the Commonwealth is not vested in the General Assembly, but in a unified judicial system, which includes the Commonwealth Court and, ultimately, this Court, which presides over our branch of government. See PA. Const, art. V, § 1.
In application, the Court has recognized that “[i]t is the province of the Judiciary to determine whether the Constitution or laws of the Commonwealth require or prohibit the performance, of certain acts. That our role may not extend to the ultimate carrying out of those acts does not reflect upon our capacity to determine the requirements of the law.” Council 13, AFSCME ex rel. Fillman v. Rendell, 604 Pa. 352, 986 A.2d 63, 75 (Pa. 2009) (quoting Thornburgh v. Lewis, 504 Pa. 206, 470 A.2d 952, 955 (Pa. 1983)). This is not a radical proposition in American law. See, e.g., Marburg, 5 U.S. at 166 (“[W]here a specific duty is assigned by law [to another branch of government], and individual rights depend upon the performance of that duty, it seems equally clear that the individual who considers himself injured, has, a right to resort to the laws of his country for a remedy.”)- Indeed, “[o]rdinarily, the exercise of the judiciary’s power to review the constitutionality of legislative action do'es not offend the principle of separation of powers,” and abstention under the political jquestion doctrine is implicated in limited, settings. See Hosp. & Healthsys. Ass’n of Pa. v. Commonwealth, 621 Pa. 260, 77 A.3d 587, 596 (Pa. 2013) (“HEAP”) (quoting Sweeney, 375 A.2d at 705).
The applicable standards to determine whether á claim warrants the exercise of judicial abstention or restraint under the political question doctrine are well[-]settled. Courts will refrain from resolving a dispute and reviewing the actions of another branch only where “the determination whether the action taken is within the power granted by the Constitution ■has been entrusted-exclusively and finally to the political branches of government for ‘self-monitoring.’” Sweeney, 375 A.2d at 706; Council 13, 986 A.2d at 76. To illustrate our approach to the political question doctrine, we customarily reference the several formulations by which the U.S. Supreme Court has described a “political question” in Baker .... See, e.g., Council 13; Thornburgh, supra.
* * * *
'We have made clear, however, that “[w]e will not refrain from resolving a dispute which involves only an interpretation of the laws of the Commonwealth, for the resolution of such disputes is our constitutional duty.” Council 13, 986 A.2d at 76 (quoting Thornburgh, 470 A.2d at 956). “[T]he need for courts to fulfill their role of enforcing constitutional limitations is particularly acute where the interests or entitlements of individual citizens are at stake.” HHAP, 77 A.3d at 597 (citing Sweeney, 375 A.2d at 709 (“[T]he political question doctrine is disfavored when a claim is made that individual liberties have been infringed.”)); accord Gondelman v. Commonwealth, 520 Pa. 451, 554 A.2d 896, 899 (Pa. 1989) (“Any concern for a functional separation of powers is, of course, overshadowed if the [statute] impinges upon the exercise of ’• a fundamental right ....”).... Responsive litigation rhetoric raising the specter of judicial interference with legislative policy does not remove a legitimate legal claim from the Court’s consideration; the political question doctrine is a shield and not a sword to' deflect judicial review. Council 13, 986 A.2d at 75-76. Furthermore, a statute is not exempt from a challenge brought for judicial consideration simply because it is said to be the General Assembly’s expression of policy rendered in a polarized political context. See id. at 76; HHAP, 77 A.3d at 598 (“[The] political question doctrine does not exist to remove a question of law from the Judiciary’s purview merely because another branch has stated its own opinion of the salient legal issue.”). Whatever the context may have been, it produced legislation; and it is the legislation that is being challenged. As the U.S. Supreme Court has stated:
The idea that any legislature ... can conclusively determine for the people and for the courts that what it enacts in the form of law, or what it authorizes its agents to do, is consistent with the fundamental law, is in opposition to the theory of our institutions. The duty rests upon all courts ... when their jurisdiction is properly invoked, to see to it that no right secured.by the supreme law of the land is impaired or destroyed by legislation. This function and duty of the judiciary distinguishes the American system from all other systems of government. The perpetuity of our institutions, and the liberty which is enjoyed under them, depend, in no small degree, upon the power given the judiciary to declare null and void all legislation that is clearly repugnant to the supreme law of the land.
Smyth, 169 U.S. at 527-28, 18 S.Ct. 418.

Robinson Twp., 83 A.3d at 927-29 (citations modified; footnote omitted); see HHAP, 77 A.3d at 596-98 (quoting Jubelirer v. Singel, 162 Pa.Cmwlth. 55, 638 A.2d 352, 358 (1994)) (“[Where petitioners allege various constitutional violations] we will not abdicate our responsibility to ‘[eft-sure that government functions within the bounds of constitutional prescription ... under the guise of deference to a co-equal branch of government. ... [I]t would be a serious dereliction on our part to deliberately ignore a clear constitutional violation.’ ”). While this Court has commented that the presence of any one Baker criterion will render the question non-justiciable, Zemprelli, 436 A.2d at 1169, we have been circumspect in our application of the political question doctrine — arguably more so recently. See Law Professors’ Amicus Curiae Brief at 18-19 & n.17 (co'unterposing six cases since 2000 in which this Court rejected political question doctrine arguments against two in which we did, one of which relied upon Marrero II),

A critical aspect of this formulation, arguably absent from Baker and its federal progeny; warrants special notice. Under our account of the textual commitment factor, we will abstain from reviewing cases only where “the determination whether the action taken is within the power granted by the Constitution has been entrusted exclusively and finally to the political branches of government for ‘self-monitoring.’” Sweeney, 375 A.2d at 706 (emphasis added); cf. Nixon, 506 U.S. at 240, 113 S.Ct. 732 (White, J., concurring) (“[T]he issue in the political question doctrine is not whether the constitutional text commits exclusive responsibility for a particular governmental function to one of the political branches. .., Rather, the issue is whether the Constitution has given one of the political branches final responsibility for interpreting the scope and nature of such a power,” (emphasis in original)). It will not suffice to prevent our review to observe that the constitutional provision in question has directed the General Assembly, not the courts, to “provide for a thorough and efficient system of public education.” The question is whether our Constitution,, explicitly or impliedly, can be read as reflecting the clear intent to entrust the' legislature with the sole prerogative to assess the .adequacy of its own effort to satisfy that constitutional mandate. If the Constitution confers upon the General Assembly the exclusive authority to monitor its own compliance with the Education Clause, that authority’s absence from the text of the Education Clause requires that it must be inferred.

C. The Teachers’ Tenure Act Case, Danson, and Marrero II

As the discussion above suggests, deciding the two questions presented, in this case requires us to examine our ruling in Marrero II, which itself adopted wholesale the Commonwealth Court’s earlier opinion in that case, see Marrero ex rel. Tabales v. Commonwealth, 709 A.2d 956 (Pa. Cmwlth. 1998) (“Marrero I”). To do so, we must first review the precedents upon which Marrero I and Marrero II relied, beginning with the Teachers’ Tenure Act Case, i.e., Malone v. Hayden, 329 Pa. 213, 197 A. 344 (1938).

In the Teachers’ Tenure Act Case, this Court confronted teachers’ mandamus challenge to the Teachers’ Tenure Act, which affected the contractual relationship between school districts and teachers subject to the Act’s ambit. “In considering laws relating to the public school system,” we held, “courts will not inquire into the reason, wisdom, or expedience of the legislative policy” at issue, but only “whether the legislation has a reasonable relation to the purpose expressed in [the Education Clause], and whether the fruits or effects of such legislation impinge on the article by circumscribing it, or abridging its exercise by future Legislatures within the field of ‘a thorough and efficient system of public schools.’ ” 197 A. at 352. Far from imposing a fixed standard upon the General Assembly, we observed, the Education Clause was designed “to enable successive Legislatures to adopt a changing program to keep abreast of educational advances. The people have directed that the cause of public education ... must evolute or retrograde with succeeding generations as the times prescribe.” Id. Thus, all matters bearing upon education, from employment contracts to “legislative determinations of school policy or the scope of educational activity, ... must at all times be subject to future legislative control.” Id. If the General Assembly does not retain such freedom, we held, “we will not have a thorough and efficient system of public schools.” Id.

It is important to note that, in that case, this Court considered whether the Teachers’ Tenure Act would preclude or interfere with future legislatures’ freedom to refine and innovate education policy, thus confounding the Education Clause’s inferred purpose to afford the General Assembly precisely such latitude. That is to say, we asked whether the incumbent General Assembly at the time had prospectively infringed the prerogative of successor legislatures. To the contrary, we found that the General Assembly’s modification of the pre-existing teacher contracts was an exercise of the legislature’s freedom to innovate and adjust education policy, noting as well that “a subsequent Legislature may abolish [the Teachers’ Tenure Act,] in toto, if it deems it necessary to do so.” Id. at 353.

Notably, we did not specifically decline to decide the constitutional challenge as a political question. Rather, we measured the challenged legislation against the Education Clause substantively without any express reservation about our authority to do so. In adopting arid applying the “reasonable relation” test, this Court assumed a deferential posture toward the General Assembly’s efforts, reflecting the judicial restraint ostensibly necessary to preserve free legislative development of education policy. However, in underscoring that any successor legislature would be free to amend or repeal the Teachers’ Tenure Act, the Court spoke forcefully against the government’s prerogative to “bargain! ] away or fetter[]” education, and emphasized that no laws, or “legislative incursions,” can be permitted to “destroy” the underlying constitutional purpose. Id. The Court thus implied that there was a body competent to ensure that such abuses did not happen. By its reference to “legislative incursions,” the Court confounded any suggestion that the General Assembly itself could be that body. Structurally, only courts might police such legislative “incursions” upon the constitutional mandate.

Nearly a half-century later, in Danson v. Casey, 484 Pa. 415, 399 A.2d 360 (1979), a case that defies confident interpretation, plaintiffs alleged that “Pennsylvania’s system of .school financing fail[ed] to provide Philadelphia’s public school children with a thorough and efficient education and de-nie[d] them equal educational opportunity solely because of their residence in the School District of Philadelphia.” Id. at 363. Plaintiffs sought injunctive relief based upon alleged violations of the Education Clause and equal protection principles enshrined by Article III Section 32. Petitioners challenged the Commonwealth’s failure to supplement the Philadelphia School District’s budget so as to “furnish the children of Philadelphia ... with a normal program of full educational services” or to ensure that “the programs of educational services ... are substantially uniform throughout all the school districts of the state.” Id. at 362-63.

This' Court first reviewed the prevailing formula by which state funds were distributed to school districts statewide, a formula that, like the current one, sought to ameliorate the hardships faced by economically disadvantaged districts. State funding notwithstanding, in fact and by design, local revenue sources remained the major source of school financing, just as they áre now. Id. at 363-64. Notwithstanding the General Assembly’s partial mitigation of the differences in resources produced by school districts’ heavy reliance upon highly variable local tax policies and tax bases, plaintiffs argued that the legislative formula was insufficient to satisfy the Education Clause’s mandate.

“More than forty years ago,” we observed in Danson, the Court “recognized [in the Teachers’ Tenure Act Case], that because educational philosophy and needs change' constantly, the words ‘thorough and efficient’ must not be narrowly construed.” Id. at 366. Reaffirming that the Education Clause must “enable successive legislatures to adopt’a changing program to keep abreast of educational advances,” id. (quoting the . Teachers’ Tenure Act Case, 197 A. at 352), we held that “[i]t would be .... contrary to the ‘essence’ of the Constitutional provision for this Court to bind future Legislatures and school boards to a present judicial review of a constitutionally required ‘normal’ program of educational services.” Id. The Court then fashioned of whole cloth the hypothesis that the only way we might “attempt to define the specific components of a' ‘thorough and efficient [system of] education’ ” in a “judicially manageable” fashion would be to impose “the rigid rule that each pupil must receive the same dollar expenditures.” Id. We noted that the framers of the 1874 Constitution, in which the Education Clause first appeared with the requirement of thoroughness and efficiency, specifically considered and rejected any suggestion that Pennsylvania’s system of public education should be uniform, instead, endorsing “local control to meet diverse local needs” and recognizing “the right of local communities to utilize local tax revenues to expand educational programs subsidized by the state.” Id. at 366-67. Thus echoing the Teachers’ Tenure Act Case, we held that the Education Clause is satisfied “as long as the legislative scheme for financing public education ‘has a reasonable relation’ to < ‘[providing] for the maintenance and support of a thorough and efficient ■ system of public schools.’ ” Id, Because the funding framework there at issue was neutral with respect to the Philadelphia School District and because it provided that district with “its fair share” of state subsidies, we concluded that the funding scheme was reasonably related “to maintenance and support of a system of public education” and thus did not violate the Education Clause. Id.

The Danson Court rejected plaintiffs’ equal protection claims with nothing more than a briéf observation that the Philadelphia School District could not be heard to complain of unequal treatment where it “arguably benefit[ed] from the operation of the school .financing scheme [because] more sources of taxation [were] made available to Philadelphia than to any other category of school district.” Id. at 867. Given the absence of reasoned analysis, Danson has very little if any precedential value regarding Petitioners’ equal'protection challenge. See Ario v. Reliance Ins. Co., 602 Pa. 490, 980 A.2d 588, 598 (2009) (Saylor, J., concurring) (quoting Commonwealth v. Perry, 568 Pa. 499, 798 A.2d 697, 707 (2002) (Castille, J., concurring) (“[Stare decisis] only applies to issues actually raised, argued and adjudicated, and only where the decision was necessary to the determination of the case.”)).

If the Danson Court’s conclusory extension of the Teachers’ Tenure Act Case to the question of justiciability was problematic, so, too, was the Court’s interjection of a critical caveat into what first seemed to be a categorical ruling. Specifically, this Court declined entirely to foreclose the possibility that a funding disparity could lead to an Education Clause violation. Instead, we distinguished cases from states in which the plaintiffs had presented evidence of “gross disparities in total and per child expenditures throughout the statefs].” Danson, 399 A.2d at 365 n.10 (citing cases from Ohio, New York, New Jersey, and California). It bears noting that, as set forth supra at length, Petitioners have alleged that per capita funding varies by nearly a three-to-one ratio from the best-funded to worst-funded schools, and have offered a litany of serious deficits among districts relating to every aspect of the educational enterprise. The Danson Court- identified no such allegations, but the ratio and other allegations set forth by Petitioners in the instant case stand in stark opposition to the vague claims described by the Danson Court. The allegations before us suggest a “gross disparity” that, if true, might sow doubt in the mind of a fact-finder regarding the thoroughness and efficiency of the education that the districts on the short end of the funding stick can hope to provide. More importantly, the Danson caveat creates a great deal of implied conflict between that opinion’s per se overtone and its more fact-sensitive distinctions of cases granting relief in other jurisdictions, cases which the Danson Court did not criticize or disavow.

Nor does this discussion exhaust Dan-son’s internal tensions. On one hand, the Danson Court embraced and purported to apply the reasonable relation test from the Teachers’ Tenure Act Case to the challenge presented. On the other, it recited the Baker factors and held that the claim was not justiciable. Complicating things still further, Danson also appeared to root its holding in the lack of “legal harm” or “legal injury” alleged, terminology invoking the discrete question of standing, the absence of which would render the claims non-justiciable for reasons wholly distinct from the political question doctrine. See Danson, 399 A.2d at 365. In sum, the Danson Court’s imprecise approach, especially viewed in tandem with the “gross disparity” qualification, undermines any effort to derive a broad principle regarding the justiciability of Education Clause and equal protection claims in the instant matter.

Then came Marrero II, the Education Clause case most like the one we now face, and the one upon which the Commonwealth relied in this case. In that case, plaintiffs sought a declaratory judgment holding that the General Assembly had failed to satisfy the Education Clause’s mandate relative to the Philadelphia School District. Plaintiffs sought an injunction directing the appropriation of additional funds for the district. The Commonwealth Court sustained the Commonwealth’s preliminary objections, holding that the claims in question were based upon matters committed solely to the discretion of the General Assembly by the Education Clause and that the case was non-justiciable on the basis that “it would be impossible to resolve the claims without making an initial policy determination of a kind which is clearly of legislative, and not judicial, discretion.” Marrero I, 709 A.2d at 966. The Commonwealth Court also found that the second Baker factor, a lack of judicially discoverable and manageable standards, precluded judicial review. See 709 A.2d at 966.

Following Danson’s dubious lead, the Marrero I court asserted baldly that the only judicially manageable standard for monitoring the legislature’s compliance with the constitutional mandate would be to impose a rigid requirement that each student receive the benefit of equal expenditures, despite the fact that plaintiffs suggested no such thing. To this premise, the Commonwealth Court responded, again without development or citation of developed authority, that expenditures alone “are not the exclusive yardstick of educational quality, or even of educational quantity.” Id. at 964 (quoting Danson, 399 A.2d at 366). Rather, the Court explained, the quality of education is dependent upon various factors, including the efficiency with which resources are utilized and the wisdom of particular expenditures. Thus, the Commonwealth Court ruled, “[a]s long as the legislative scheme for financing public education ‘has a reasonable relation’ to ‘[providing] for the maintenance and support of a thorough and efficient system of public schools,’ [Teachers’ Tenure Act Case, 197 A. at 352,] the General Assembly has fulfilled its constitutional duty.” Marrero I, 709 A.2d at 964 (quoting Danson, 399 A.2d at 367). The Commonwealth Court determined that the financing scheme enacted by the General Assembly was reasonably related to its constitutional mandate and was neutral with regard to the district, providing that district with a “fair share” of state subsidies. Consequently, the legislative scheme did not violate the Education Clause. Having so declared, the Commonwealth Court then circled back to observe, in the same terminology applied in the Teachers’ Tenure Act Case, that it would “not inquire into the reason, wisdom, or expediency of the legislative policy with regard to education, nor any matters relating to legislative determinations of school policy 'or the scope of educational activity.” Id. at 965. Thus, in Mamro I, as in Danson, and unlike in the Teachers’ Tenure Act Case upon which both decisions purported to rely, the court deemed the question non-justiciable, even as it utilized language suggesting its review and rejection of the underlying challenge on the merits. Marrero I, 709 A.2d at 965-66.

The Teachers’ Tenure Act Case, Dan-son, and Mamro II necessarily inform our consideration regarding the justiciability of Petitioners’ Education Clause and equal protection claims. But to rely uncritically upon their analyses and holdings would be to rest our decision upon an unstable three-legged stool. The account above makes clear just how- little weight that stool can bear. The first of these three cases assessed legislative discretion alone, implicitly and necessarily treating a claimed violation of the Education Clause as justiciable. The Teachers’ Termre Act Case can be construed either as establishing a standard of review by which to review Education Clause challenges, in the form of the reasonable relation test, or as one cursorily dismissing plaintiffs’ claim upon the strength of future legislatures’ discretion to modify education policy. In fact, that future legislative discretion was not impaired by the Act in question, given that the Act could be repealed or amended at any time. Then, in Danson, the Court seemed to vindicate deferential merits review in its recitation and apparent application of the, reasonable relation standard, only to follow that with what appeared to be a determination that the challenge was not justiciable. The Court based this pivot upon the manifestly debatable premises that: (a) the only judicially discoverable and manageable standard for -resolving such, a challenge would be to require equal per capita expenditures statewide; and (b) the imposition of any judicially-defined standard whatsoever necessarily would preclude the General Assembly’s continued salutary experimentation with education policy. Then came Marrero I and II, wherein the Commonwealth Court, and then, this Court, adopted Danson wholesale, warts and all, again applying the political question doctrine and reasonable relationship test simultaneously — and irreconcilably.

For what little developed reasoning there is to be gleaned from our prior three cases, we must conclude that the slate relative to the instant challenges is, if not clean, then at least relatively unadorned by any harmonious rule of law that controls the instant matter. Thus, in addressing Petitioners’ claims in this ease, we must consider anew the Baker factors as to each claim.

D. Justiciability and the Education Clause

In evaluating the factors and their application to Petitioners’ Education Clause claim, we focus upon the first three factors: a -textually demonstrable commitment to the General Assembly, a lack .of judicially discoverable and manageable standards, and an inability to decide the question without an initial-policy determination not appropriate for judicial discretion. These three factors .are closely interrelated

1. Textual Commitment

With- regard to the textual commitment factor, Sweeney and Robinson Township, inter alia,; have made clear that mere textual commitment of a given function to a given branch of government does not by itself preclude'judicial review. See, e.g., Robinson Twp., 83 A.3d at 928 (“Courts will refrain from resolving a dispute and reviewing the actions of another branch only' where the determination whether the action taken is within the power granted by the Cónstitution has been entrusted exclusively and finally to the political branches of government for self-monitoring.”)* (internal quotation marks Omitted). Thus, there must be some indication'that vested within the Education Clause mandate is the obligation and prerogative to “self-monitor.” That the mandate charges the General Assembly with maintaining and supporting “a thorough and efficient system of public education”- by no means implies that the legislature’s efforts at doing so may be graded exclusively by that body without judicial' recourse. We find no evidence from which to draw such a broad conclusion when it is antithetical to our prior stringent accounts of the textual commitment factor in Sweeney, Robinson Township, and other cases. This is especially so in light of the well-documented suspicion with which the framers of the 1874 Constitution viewed legislative overreach. Thus, any such implication must lie in the close relationship-between the textual commitment factor and the lack of judicially -discoverable and manageable standards factor that has been recognized in the past. See Nixon, 506 U.S. at 228-29, 113 S.Ct. 732.

2, Judicially Manageable Standards and Initial Policy Determinations

In proposing a basis upon which to harmonize rather than abrogate our pri- or decisions, Petitioners, in sum, suggest that the recent proliferation of federal and state curricular mandates, in tandem with elaborate student assessment and school accountability measures, reflect a sea change in the legislative imposition of standards. Specifically, the advent of the modern era of Common Core curricula, and elaborate tools for assessing educational success, such as the PSSA and Keystone Exams, contradict any argument that there are no judicially enforceable standards that might apply to test the General Assembly’s satisfaction of its mandate. And because a court can rely upon standards already established by the legislature to make a circumstance-specific determination of educational adequacy without fashioning a fixed baseline standard out of whole cloth, judicial oversight does not require an intrusion upon the General Assembly’s policy-making function. Petitioners explain as follows:

After defining what children should learn in school (and imposing significant consequences on those who fall short), the legislature has a duty under the Education Clause to provide funding sufficient to ensure that all students are given an opportunity to actually learn it. That duty flows from the plain language of the Education Clause .... The legislature’s current definition of a “thorough and efficient system of public education” — as related in state academic standards and other legislative enactments — thus defines the scope of its financial support obligations. In other words, the Constitution requires the legislature to maintain and support the sys-tern that the legislature itself has mandated.

Brief for Petitioners at 33-34.

Petitioners reinforce this line of reasoning by reviewing other state courts that have applied it in reviewing (on the merits) legislative compliance with their respective education clauses. Petitioners acknowledge that some school districts may have poor test results due to “local mismanagement or ineffective teachers,” even where the General Assembly has allocated the resources necessary to provide the education that the legislature itself has demanded. But Petitioners underscore that this is distinct from judicially assessing the alleged systemic- inability of many school districts to satisfy legislative standards' given their limited resources, an infirmity curable only with greater state assistance, given certain districts’ limited property tax bases and taxing authority. By way of reinforcement, Petitioners review their pleading’s allegations and recite a series of “abysmal” performance numbers from various school districts. Id. at 36 (citing Petition at 65-67 ¶ 156). They underscore that universal satisfaction of performance thresholds is not the goal. Rather, the General Assembly’s obligation lies in providing sufficient support to all school districts to ensure that their students have the opportunity to meet the General Assembly’s and Department of Education’s stated thresholds.

With regard to the funding component of providing such support, Petitioners point to the 2006-08 costing-out study ordered and obtained by the General Assembly. They contend that, while the General Assembly effectively has defined an “adequate” education either through, or at least by inference from, the various performance standards it has imposed upon school districts, it also has access (as do the courts) to its own district-by-district costing-out study. This study may be used to determine whether the state’s financial support, in its magnitude and distribution, provides the opportunity to succeed relative to the state’s own benchmarks.

As to Bakers “initial policy judgment” factor, Petitioners seek to distinguish, in effect, holding the General Assembly’s feet to the fire broadly from conducting a full inquisition on the particulars. Petitioners suggest that no such policy judgment need be made in assessing the adequacy of the resources dedicated by the General Assembly to support fulfillment of objectives delineated by that selfsame body. Petitioners close by reviewing various decisions from other jurisdictions in which courts “crafted effective and noninvasive remedies to address education clause violations.” Id. at 41^3. In light of these developments over the past twenty years, Petitioners argue that it is incongruous for Respondents now to maintain that it is impossible for a court to fashion a constitutional threshold for educational adequacy-

Respondents reply that it would be unreasonable to take a snapshot of legislative standards at a moment in time and confer constitutional status upon that snapshot. They suggest that, at any given moment, the legislature may be doing far more than any reasonable interpretation of the Constitution would require, implicitly arguing that the General Assembly should retain latitude to do less. Respondents further argue that to adopt a fixed constitutional standard based upon any particular suite of benchmarks imposed by the General. Assembly limits the legislative freedom to experiment with education policy in response to changing needs and innovations. The necessity of this freedom is precisely the one unequivocal proposition that may reasonably be inferred from the Teachers’ Tenure Ad Case, Dansón, and Marrero II. Alternatively, if a court was to enshrine the standards of the moment as the constitutional threshold, but leave open the door to future legislative changes with the expectation that those standards then would become constitutional, such a holding would render our own rulings merely perfunctory. More perniciously, Respondents say, the General Assembly might be encouraged to lower standards simply to deflect whatever judicial oversight might remain, enshrining utter and de facto legislative prerogative without acknowledging it as such.

Respondents then adopt the dubious premise accepted without material explanation by the Danson and Marrero II Courts that financial equalization offers the only judicially manageable standard. To impose such a standard would confound the constitutional design in numerous particulars. First, it would contradict the framers’ specific consideration and rejection of a uniformity requirement. Second, it would undermine the enduring emphasis on local prerogatives that long has animated education policy in the Commonwealth and elsewhere.

It is true.that Petitioners lean heavily upon the strict academic standards embodied in the General Assembly’s measures of educational success, without expressly allowing that the constitutional threshold found by a court might lie somewhere below that level or be differently described. See Petition at 120-21 ¶¶ 313-14, 320-21 (seeking a court order directing, inter alia, that the General Assembly establish a “school! financing arrangement that is reasonably calculated to ensure that all students in Pennsylvania have an op-, portunity to obtain an adequate education that will enable them to meet state aea-demic standards”). It: is reasonable to maintain that these measures necessarily are mutable, and are ill-suited, as such, to serve as a constitutional minimum now or in the future. Nonetheless, Petitioners also request relief aimed at a more general purpose: a declaration that the General Assembly must provide the “support necessary to ensure that all students have the opportunity to obtain an adequate education that will enable them to ... participate meaningfully in the economic, civic, and social activities of our society.” Id. at 120-21 ¶ 314. This is distinct from Petitioners’ parallel prayers for the relief they seek in explicitly financial terms or in terms of the curricular mandates of the moment. That is to say, Petitioners’ reliance upon today’s statutory or regulatory standards, or any particular standardized testing measures, is by no means exclusive.

Even when Petitioners speak in financial terms, they do not conjure the straw man of funding equality or fixed standards so critical to this Court’s reasoning in Danson and Marrero II. To the contrary, they posit that there exists a threshold level of “adequacy” that is a condition precedent to systemic thoroughness and efficiency in the constitutionally-intended sense for which the General Assembly-is responsible. Consonantly, Petitioners never dispute that individual districts should be free to utilize local funding sources to elevate their standards above the constitutional floor. Accordingly, we will not impute to Petitioners the desire for funding equality that, once posited, necessarily short-circuits an appropriately rigorous discussion of how courts might ensure that the Education Clause is more than merely hortatory without unduly infringing legislative prerogatives.

If we accept Respondents’ framing, the question of standards answers itself. Surely, it cannot be correct that we simply constitutionalize whatever standards the General Assembly relies upon at a moment in time, and then fix: those as the constitutional minimum moving forward, if only because at .that point our oversight function would be merely symbolic. But we must remember that the question presented is not what standard a court might émploy in assessing the General Assembly’s satisfaction of its mandate, but whether any conceivable judicially enforceable standard might be formulated and applied after the development of an adequate record consisting of ah array of proposals as to how a court might fairly assess thoroughness and efficiency. That Petitioners focus upon the web of standards presently imposed upon districts by the General Assembly and the Department of Education as offering judicially enforceable standards for constitutional purposes does not mean that wé should decide at this juncture whether those standards are suitable. Nor does it foreclose the prospect that the Commonwealth Court on remand may fashion an entirely different standard, as is its prerogative by virtue of Petitioners’ request for “such other and further relief as the [e]ourt may deem just and proper.” Petition at 123 ¶ 324; see Lower Frederick Twp. v. Clemmer, 518 Pa. 313, 543 A.2d 502, 512 (1988) (“A prayer for general relief is as broad as the equitable powers of the court. Under such a prayer a chancellor in equity may grant any relief that is consistent with the theory and purpose of the action.”); Meth v. Meth, 360 Pa. 623, 62 A.2d 848, 849 (1949) (same).

It would be folly to suggest that creating a practicable standard by which courts might define and measure the' thoroughness and efficiency of a given statutory educational scheme presents no formidable challenge. But we are not called upon to propose such a definition now. Our sister states,■ which have sought to-do so by reference to the history of their own-constitutions, have taken the most sensible approach. See, e.g., Hornbeck v. Somerset Cnty. Bd. of Ed., 295 Md. 597, 458 A.2d 758, 770-81 (1983). Because their histories are not ours, only their analytic approach is relevant at this juncture. The results of such an inquiry in Pennsylvania may vary.

The examples offered by other jurisdictions are worth reviewing, if only to gain some sense of what happens when a court does not shy away ■ from developing a broad, flexible judicial standard for assessing legislative fulfillment of a constitutional mandate to furnish public education while remaining sensitive to the legislature’s sole prerogative to negotiate the particular policies that will satisfy it. The West Virginia Supreme Court, whose education clause provides that “[t]he Legislature shall provide, by general law, for a thorough and efficient system of free schools,” after carefully surveying the history of the framing of its clause, set forth the following standard:

[A thorough and efficient system of schools] develops, as best the state of education expertise allows, the minds, bodies and social morality of its charges to prepare them for useful and happy occupations, recreation and citizenship, ■and does so economically.
Legally recognized elements in this definition are development in' every child to his or her capacity of (1) literacy; (2) ability to add, subtract, multiply and divide numbers; (3) knowledge of government to the extent that the child will be equipped as a citizen to make informed choices among persons and issues that affect his own governance; (4) self-knowledge and knowledge of his or her total environment to allow the child ‘to intelligently choose life work to know his or her options; (5) work-training and advanced academic training as the child may intelligently choose; (6) reereational pursuits; (7) interests in all creative arts, such as music, theatre, literature, and the visual arts;: (8) social ethics, both behavioral and abstract,- to facilitate compatibility with others in this :society. , ,
Implicit are supportive- services: (1) good physical facilities,- instructional materials and personnel; (2) careful state and local supervision to prevent waste and,to monitor pupil, teacher and administrative competency.

Pauley v. Kelly, 162 W.Va. 672, 255 S.E.2d 859, 877 (1979); see Leandro v. State, 346 N.C. 336, 488 S.E.2d 249, 255 (1997) (providing a similar enumeration of goals); see also Campaign for Fiscal Equity, Inc. v. State, 100 N.Y.2d 893, 769 N.Y.S.2d 106, 801 N.E.2d 326, 330 (2003) (“[W]e equate a sound-basic education with the basic literacy, calculating, and verbal-skills necessary tó enable 'children to 'eventually function productively as civic participants capable of voting and serving-, on a jury.”). The Supreme Courts of both Washington and Tennessee focused on defining education itself.

■ Notably, the chapter of the Pennsylvania Administrative Code that concerns academic standards and assessment offers an aspirational account of what the public education system should provide each student. It essentially echoes the standards offered in Pauley and Leandro, supra:

Purpose of public education.
(a) This section and § 4.12 (relating to academic standards) describe the purpose of public education and its relationship with the academic standards.
(b) Public education prepares students for adult life by attending to their intellectual and developmental needs and challenging them to achieve at their highest level possible. In conjunction with families and other community institutions, public education prepares students to become self-directed, life-long learners and responsible, involved citizens.
(c) Together with parents, families and community institutions, public education provides opportunities for students to:
(1) Acquire knowledge and skills.
(2) Develop integrity.
(3) Process information.
(4) Think critically.
(5) Work independently.
(6) Collaborate with others.
(7) Adapt to change.
(e) Achievement of high academic standards in public education is dependent upon the quality of instruction in schools and student effort supported by the involvement of family and community.
****
(g) Public schools provide instruction throughout the curriculum so that students may develop knowledge and skills in the following areas:
(1) English language arts.
(2) Mathematics.
(3) Science and technology.
(4) Environment and ecology,
(5) Social studies (civics and government, geography, economics and history).
(6) Arts and humanities.
(7) Career education and work.
(8) Health, safety and physical education.
(9) Family and consumer science.

22 Pa. Code § 4.11 (amended Feb. 16, 2008, Oct. 16, 2010, and Mar. 1, 2014). In light, of this formulation, it is somewhat incongruous for Respondents to maintain that there is no prospect that a court could fashion a constitutionalized account not unlike this one, and measure the state of public education against that rubric, just as other states have done.

The widespread recognition that the essential concepts at issue are amenable to definition underscores the difficulty with a per se rule of non-justiciability. It is instructive that so many other states have found claims under their respective education clauses to be justiciable, either explicitly in the face of political question challenges, or implicitly by analyzing at length the merits of the challenges at issue. See Conn. Coal. for Justice in Educ. Funding, Inc., v. Rell, 295 Conn. 240, 990 A.2d 206, 225 n.24 (2010) (citing cases to establish that “the vast majority of jurisdictions ‘overwhelmingly’ have concluded that claims that their legislatures have not fulfilled their constitutional responsibilities under their education clauses are justicia-ble”). Most compelling are those cases that address constitutions employing the “thorough and efficient” language familiar from our own Education Clause. In addition to West Virginia, these include Maryland, Minnesota, New Jersey, Ohio, Wyoming, and Illinois. It also is useful to consider those cases in tandem with cases reviewing other education clauses that employ qualitative language — i.e., that which is amenable to interpretation — which ' by and large have been treated as justiciable. Still other states have considered the merits of challenges to constitutional provisions that arguably do not employ qualita-five language. Conversely, a minority of courts have declined the judicial review function entirely on precisely the grounds that Respondents invoke now.

These many decisions stand for the proposition that courts in a substantial majority of American jurisdictions have declined to let the potential difficulty and conflict that may attend constitutional oversight of education dissuade them from undertaking the task of judicial review. Their methods of doing so, the standards and rigor they employ, and the degree of their deference to legislative determinations vary, as do the results of the eases they have considered. That a case is entertained on the merits hardly guarantees victory for either side. But it cannot be said that the inability to fashion a tidy, mechanical standard of review for such challenges has prompted many other states to abandon their judicial function.

Respondents argue, in effect, that this Court cannot define thoroughness and efficiency while still respecting the legislature’s primacy in ■ fashioning educational policy and preserving its ongoing flexibility to refine that policy to reflect pedagogical advances and. to adapt to changing times and evolving needs. But centuries of litigation leading to judicially enforceable definitions of such vague terms as “probable cause,” “due process,” “equal protection,” and “cruel and unusual punishment” undermine the argument. Courts give meaning routinely to all manner of amorphous constitutional concepts, including those that lie at the'intersection of legislative prerogative and judicial review. And they do so while still leaving room for future development by whatever government body or mechanism the law; fairly prescribes. Nor is this a phenomenon reserved for fundamental rights. The United States Supreme Court has given judicial meaning to such nebulous terms as “interstate commerce.” Cf. Nixon, 506 U.S. at 246-47, 113 S.Ct. 732 (White, J., concurring) (noting that the Court has taken it upon itself to construe constitutional termir nology such as “commerce,” which it did in Gibbons v. Ogden, 22 U.S. 1, 72, 9 Wheat. 1, 6 L.Ed. 23 (1824), and, more famously, “due process of law”); Baker, 369 U.S. at 226, 82 S.Ct. 691 (“Judicial standards under the Equal Protection Clause are well[-]developed and familiar .... ”).

The same is true of this Court. Recently, in Robinson Township, we rejected a justi-ciability challenge to claims that certain legislative actions failed to pay due regard to Article I, Section 27 of our Constitution, commonly referred to as the Environmental Rights Amendment. There, we were called upon to give enforceable meaning to terms like “clean air [and] pure water,” “preservation of the natural, scenic, historic and esthetic values of the environment,” and “natural resources,” and we undertook to delineate how the Commonwealth might satisfy its mandate to “conserve and maintain [these natural resources] for the benefit of all the people.” See Robinson Twp., 83 A.3d at 969 (Opinion Announcing the Judgment of the Court). We rejected the suggestion that the question was so political as to remove it from our purview. Surely, these terms are no more amenable to precise definition and mechanical application than a “thorough and efficient system of public education.”

We must at times return a case to a legislative body for further action with only a broadly-stated mandate to serve as guidance. This was the effective outcome in Robinson Township. Furthermore, we have allowed claims to proceed even when the remedy might require increased funding for a government function, where the precise amount of funding necessary is not amenable to easy quantification. See Kuren, 146 A.3d 715 (reversing dismissal of injunctive claim based upon prospective violations of right to counsel due to county underfunding of indigent criminal defense resources); cf. Pa. Env’l Defense Found. v. Commonwealth, 161 A.3d 911 (Pa. 2017) (holding that the Environmental Rights Amendment, PA. Const, art. I, § 27, imposes limitations, previously unrecognized, upon how the Commonwealth may dispose of the net proceeds of sales of public natural resources). And in Pennsylvania Human Relations Commission v. Chester School District, 427 Pa. 157, 233 A.2d 290 (1967), finding that a school district was too racially segregated to pass constitutional muster (a determination that, itself, required a necessarily imprecise assessment), we upheld an administrative order directing the school district through its board, officers, and agents to submit a desegregation plan. Perhaps most notably, in Holt v. 2011 Legislative Reapportionment Commission, 614 Pa. 364, 38 A.3d 711 (2012), we rejected a proposed legislative redistricting plan, notwithstanding the limited guidance we could offer the commission in remedying the constitutional failings that we had identified.

To the extent that our prior cases have suggested, if murkily, that a court cannot devise a judicially discoverable and manageable standard for Education Clause compliance that does not entail making a policy determination inappropriate for judicial discretion, or that we may only deploy a rubber stamp in a hollow mockery of judicial review, we underscore that we are not bound to follow precedent when it cannot bear scrutiny, either on its own terms or in light of subsequent developments. “Although this Court adheres to the principle of stare decisis, it will not be bound by a decision that in itself is clearly contrary to the body of the law. In such instances, it is consistent with the principle underlying stare decisis to purify- the body of law by overruling erroneous decisions.” Lewis v. W.C.A.B. (Giles & Ransome, Inc.), 591 Pa. 490, 919 A.2d 922, 928 (2007); see Ayala v. Phila. Bd. of Public Ed., 453 Pa. 584, 305 A.2d 877, 887-88 (1973), superseded by statute as recognized in Dorsey v. Redman, 626 Pa. 195, 96 A.3d 332 (2014) (“[I]f, after thorough examination and deep thought a prior judicial decision seems wrong in principle or manifestly out of accord' with modern conditions of life, it should not be followed as controlling precedent”). As this Court previously has recognized, “[w]here ... by our decisions ... the Court distorted the clear intention of the legislative enactment and by that erroneous interpretation permitted the policy of that legislation to be effectively frustrated, we .. have no alternative but to rectify our earlier pronouncements and may not blindly adhere to the past rulings out of a deference to ■ antiquity.” Perry, 798 A.2d at 707 & n.1 (Castille J., concurring) (quoting Mayhugh v. Coon, 460 Pa. 128, 331 A.2d 452, 456 (1975), and observing that the principle “is no less applicable to constitutional provisions”).

We find irreconcilable deficiencies in the rigor, clarity, and consistency of the line of cases that culminated in Marrero II. When presented with a case that hinges upon our interpretation and application of prior case law, the validity of that case law always is subject to consideration, and we follow the exercise of our interpretive function wherever it leads. Cf. Commonwealth ex rel. Margiotti v. Lawrence, 326 Pa. 526, 193 A. 46, 48 (Pa. 1937) (quoting 1 Cooley, Constitutional Limitations 121 (8th ed. 1977)) (“[W]hen a question involving important public or private rights, extending through all coming time, has been passed upon on a single occasion, and which decision can in no just sense be said to have been acquiesced in, it is not only the right, but the duty, of the court, when properly called upon, to re-examine the questions involved, and again subject them to judicial scrutiny.”).-

For the foregoing reasons, we reject Respondents’ and the lower courts’ artificially narrow account of how a court may go about reviewing Education Clause challenges. We do not take at face value Petitioners’ attempt to constitutionalize the standards of the day. But we agree with the broader proposition — long accepted by dozens of our sister courts — that it is feasible for a court to give meaning and force to the language of a constitutional mandate to furnish education of a specified quality, in this case “thorough and efficient,” without trammeling the legislature in derogation of the separation of powers. This, of course, does not suggest that Petitioners’ claims, or those of 'any future litigant, should or will prevail. The parties have had no opportunity to develop the historic record concerning what, precisely, thoroughness and efficiency were intended to entail, nor have they had an opportunity to develop a recqrd enabling assessment of the adequacy of the current funding scheme relative to any particular account of the Constitution’s meaning. We hold merely that Petitioners’ claims cannot be dismissed as non-justiciablé.

E. Justiciability and Equal Protection

Petitioners’ equal protection claim sounds in Article III, Section 32 of the Pennsylvania Constitution, not the Fourteenth Amendment to the United States Constitution. See supra n.3. However, we have held that the substantive content of .the two provisions does not differ significantly. Balt. & Ohio R. Co. v. Dep’t of Labor & Indus., 461 Pa. 68, 334 A.2d 636, 643 (1975)); accord Commonwealth v. Albert, 563 Pa. 133, 758 A.2d 1149, 1151 (2000). Hence, we may consider them together. Section 32 embodies the principle that “like persons in like circumstances should be treated similarly by the sovereign.” Robinson Twp., 83 A.3d at 987.

Under a typical [equal protection] analysis of governmental classifications, there are three different types of classifications calling for three different standards of judicial review. The first type— classifications implicating neither suspect classes nor fundamental rights— will be sustained if it meets a “rational basis” test. In the second type of case[ ], where a suspect classification has been made or a fundamental right has been burdened, another standard of review is applied: that of strict scrutiny. Finally, in the third type of cases, if “important,” though,not fundamental rights are affected by the classification, or if “sensitive” classifications have been made, the United States Supreme Court has employed what may be called an intermediate standard of review, or a heightened standard of review.

James v. Southeastern Pennsylvania Transp. Authority, 505 Pa. 137, 477 A.2d 1302, 1305-1306 (1984). When applicable, strict scrutiny under equal protection requires the court to determine whether the classification is necessary to advance a compelling state interest. D.P. v. G.J.P., 636 Pa. 574, 146 A.3d 204, 210 (2016). If the rational basis test applies, then the classification in question must be “reasonable rather than arbitrary and bear a reasonable relationship to the object of the legislation.[] In other words, a classification must rest upon some ground of difference which justifies the classification and have a fair and substantial relationship to the object of the legislation,” Albert, 758 A.2d at 1151 (citation omitted), Since-Petitioners undisputedly do not claim to comprise a class historically recognized as “suspect” under the United States or Pennsylvania .Constitutions, they are entitled to elevated scrutiny only if they establish that they have an important or fundamental right to education. Failing that, Petitioners will prevail on their equal protection claim only if they establish that the school finakcing legislation, has no rational basis for the classification it utilizes in allocating funds at the district level.

Although it did not do so in clear terms, it is difficult to understand the Commonwealth Court’s conclusory rejection of Petitioner’s equal protection claim as relying upon anything other than this Court’s approach in Danson, in which we uncritically linked the plaintiffs equal protection claim to the. Education Clause. To , that extent, the Commonwealth Court’s ruling in this case suffers from the same faults that have led us to identify little of precedential value in Danson. Indeed, the Commonwealth Court’s disposition of the equal protection claim in the instant case depends so completely upon the outcome of the Education Clause claim that we could simply remand with direction that it consider that issue in light of our ruling with regard to the Education Clause. However, because we think it wrong to conflate Petitioners’ equal protection claim with their Education Clause claims, we think it prudent to discuss their justiciability independently.

Despite some inevitable degree of overlap, Petitioners’ pleading establishes the independence of their equal protection claim from their Education Clause claim. For example, Petitioners allege classifications by which even with the benefit of a relatively higher share of state funding some districts still have radically less to spend on their students than other districts that also receive state funding, albeit in smaller measure. And-it-is the classifications, not the absolute amounts, that form the basis of Petitioners’ claims. See Petition at 5- ¶ 7 (“[T]he very low levels of state funding and unusually high dependence on local taxes under the current financing arrangement ‘have created ‘gross funding disparities among school districts — an asymmetry that disproportionately harms children residing in districts with low property values and incomés.”), 5 ¶8 (noting that “total education expenditures, per student now range from as little as $9,800 per student in school districts with low property, values and incomes to more than $28,400 per student in districts with high property values and incomes,” an “unconscionable and irrational funding disparity [that] violates the Equal Protection Clause”); 32 ¶ 94 (“A school financing arrangement that denies children residing in school districts with low property values and incomes the opportunity to obtain an adequate education, while, providing ■sufficient resources to children in school districts with high property values and incomes, is unconstitutional.” (emphasis added)). Further, as set forth at length, supra, even setting aside entirely the question of money, Petitioners assert myriad deficiencies in facilities and educational materials, staffing, programming, and so on that are not specifically couched in terms of funding, and that conceivably could' be rectified by means other than increasing monetary allocations to the districts in question.

In alleging the Commonwealth’s failure “to finance the Commonwealth’s public education system in a manner that does not irrationally discriminate against a class of children,” id. at 2 ¶1 (emphasis added), it is clear that it is the manner of distribution, not the quantum of financial resources distributed, that drives this claim. Moreover, Petitioners’ prayer for relief reinforces the distinction between their equal protection and Education Clause arguments. See, e.g., id. at 8 ¶13 (seeking an injunction compelling the - legislature to halt any funding, arrangement that “irrationally discriminates against children who live in school districts with low property values and incomes”); 121 ¶ 316 (seeking a declaration that-equal protection “imposes upon Respondents an obligation to adopt a sehool[ ]financing arrangement that does not discriminate against-students based on the amount of incomes and taxable property in their -school districts”). In short, Petitioners’ equal protection claims focus upon “the method by which education funds are raised and distributed — not the overall amount of funding.” Brief for Petitioners at 26.(emphasis in original). Thus, the Commonwealth Court erred to the extent that it determined that the fate of Petitioners’ equal protection claims necessarily is tied to .that of their Education Clause claims. ... ;

Treating Petitioners’ equal protection claims as distinct leaves us with little basis upon which to deem them non-justiciable. On the question of justiciability, Respondents primarily rely upon the proposition that the fate of Petitioners’ Education Clause claims dictates the fate of their equal protection claims. But our determination that the Education Clause claims are justiciable is fatal to that argument.

Application of the Baker factors does not suggest a different result. To the extent that Petitioners’ equal protection claim is tied to then- Education Clause claim, the foregoing analysis governs, and the equal protection claim is justiciable. But treating the claims separately, we find no analysis by the Commonwealth Court, no argument by Respondents, nor anything in law to suggest how Petitioners’ equal protection claim does not survive Baker scrutiny. If the Education Clause does not textually repose in the General Assembly the authority to self-monitor and self-validate its compliance with that provision, certainly Article III, Section 32 does not do so, and no one suggests otherwise. Furthermore, there is little question that the rational basis/heightened scrutiny/strict scrutiny rubric that applies to equal protection claims is, by its very nature, a judicially discoverable and manageable standard, and one that does not require a policy determination that properly belongs to the legislature.

Of course, there is no question that, in addressing the latter two Baker concerns, the substance of the underlying legal issue informs the question of standards — the very phrase “equal protection of the law” presupposes some other law that must be applied equally to similarly situated parties. But in that sense, we find ourselves confronting our ruling as to the justiciability of the Education Clause claim, which leads to the same result in this instance. All of which is to say, our foregoing ruling effectively compels us to determine that Petitioners’ equal protection claim is justi-ciable in the general sense. Neither the lower court nor Respondents suggest otherwise. Even if that were not the case, Petitioners’ allegations raise the sort of equal protection questions that we nearly always treat as justiciable: Whether there exists a classification; whether it is suspect or subject to heightened scrutiny; whether it burdens a fundamental right; and whether the law is appropriately fashioned relative to the applicable standard of review. These are all commonplace inquiries in the courts, and involve neither un-discoverable nor unmanageable standards. Nor do they implicate initial policy considerations best left to the legislature. Rather, the court measures the legislature’s initial policy consideration against a familiar, time-honored rubric that courts have applied on innumerable occasions.

In rebutting the existence of an individual right to education, Respondents rely in part on the United States Supreme Court’s decision in San Antonio Independent School District v. Rodriguez, 411 U.S. 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973). There, the Court faced a federal Equal Protection Clause challenge to the system by which Texas distributed state education funding, a challenge substantively quite similar to the claim at issue in the instant case. The Court ruled adversely to the plaintiffs in part based upon its determination that there is no right to education to be found in the United States Constitution. That was a consequence of the United States Constitution’s conspicuous and complete silence on the very topic of education. This renders the High Court’s determination on the question of an individual right immaterial to the Pennsylvania Constitution, which, obviously, is not at all silent on the topic. What is important to note in connection with this claim, however, is that the Court, as bound by Baker and its progeny as we are, did not find the challenge non-justiciable as a political question. Rather, the Court engaged in a quite lengthy analysis of the merits of the claim. Thus, in citing Rodriguez, Respondents effectively reinforce that Petitioners’ equal protection claims are justiciable without regard to the viability of their Education Clause claims.

This leaves the question of what sort of right is at issue. In turn, this will dictate what standard of review applies to Petitioners’ equal protection claim, should it proceed. We need not resolve that question presently, but we underscore that whether education is a fundamental right under Pennsylvania law is not a settled question simply because Danson and Marrero II suggested as much. To the contrary, we do not read any of our prior cases as settling whether the Pennsylvania Constitution confers an individual right to education— and, if so, of what sort. In the Teachers’ Tenure Act Case, this Court distinguished a Pennsylvania with the benefits of mandated public education from one in which education is “scarce,” “a privilege of the rich.” 197 A. at 352. This might be taken as support for the proposition that the framers intended that what was once “a privilege of the rich” would, through the Education Clause, become a right vested in all Pennsylvanians. To similar effect, in School District of Philadelphia v. Twer, this Court observed that “financial concerns could not in any way dilute the primary responsibility to maintain ‘a thorough and efficient system of public schools,’ ” and “that the maintenance of a public school system is primarily for the education and training of our youth.” 498 Pa. 429, 447 A.2d 222, 224 (1982). Thus, “the polestar in any decision-requiring the assignment of priorities of resources available for education must be the best interest of the student.” Id.

Most explicit, of course, is our dictum in School District of Wilkinsburg v. Wilkinsburg Education Association: “[P]ublic education in Pennsylvania is a fundamental right. It is required by Article III, Section 14 of the Pennsylvania Constitution.” 542 Pa. 335, 667 A.2d 5, 9 (1995). However, in Danson, albeit implicitly, we rejected the notion that there Was an individual right to education, a proposition that we made explicit in Marrero II. There, we approved what we characterized as Damon’s holding that our Constitution's educational mandate does not confer an “individual right upon each student to a particular level or quality of education.” Marrero II, 739 A.2d at 112. The simple fact is that none of-these cases conclusively decided the question, and to read any of them to the contrary is to confer upon them more precedential value on that question than they warrant. Furthermore, the mixed signals we may glean from our decisional law echo the conflicting array of rulings in other state courts confronting the same question. We should not treat as settled a question that we have never answered conclusively.

For the foregoing reasons, we hold that the Commonwealth Court erred in determining that Petitioners’ equal protection claim presented a nori-justiciable political question. Viewed as necessarily derivative of Petitioners’'Education Clause claim, Petitioners’ equal protection claim is justicia-ble for the reasons set forth above. Viewed as an independent claim, we discern no basis in prior precedent or the arguments of the Respondents to establish that any of the Baker factors apply independently to bar judicial review. We decline at this time to address what individual right to education Petitioners may have, and concomitantly what level of scrutiny should apply to Petitioners’ claims, as these issues lie outside the ambit of the justiciability question we are called upon- to answer here. It suffices at this time to note that our prior precedent is inconclusive. We intend only to dispel any notion that our decision in Marrero II resolved the question as a matter of law.

IV. Conclusion

Two decades after Marbury, in another paean to the importance of judicial review, Chief Justice Marshall cautioned that “[t]he judiciary cannot, as the legislature may, avoid a measure because it approaches the confínes of the [Constitution. We cannot pass it by because it is doubtful. With whatever doubts, with whatever difficulties, a case may be attended, we must decide it, if it be brought before us.” Cohens v. Virginia, 19 U.S. 264, 404, 6 Wheat. 264, 5 L.Ed. 257 (1821). The spirit of Chief Justice Marshall’s cautionary refrain has informed the clear majority of state courts that have held it their judicial duty to construe interpretation-begging state education clauses like ours to ensure legislative compliance with their constitutional mandates, no matter the difficulties invited or, in many cases, confronted. We hold that our Education Clause, viewed in the overarching context of our cases taking up the question of abstention from political questions, compels the same result. To the extent our prior cases suggest a contrary result, they must yield.

To be sure, courts must take great care in wading deeply into questions of social and economic policy, which we long have recognized as fitting poorly with the judiciary’s institutional competencies. See, e.g., Martin v. Unemployment Comp. Bd. of Review, 502 Pa. 282, 466 A.2d 107, 111-13 (Pa. 1983). However, the judiciary has a correlative and equally important obligation to fulfill its interpretive function. It bears repeating that the political question doctrine in Pennsylvania is of wholly prudential cloth, and hence must be considered anew each time it is invoked. See supra at 436-38. It is a mistake to conflate legislative policy-making pursuant, to a constitutional mandate with constitutional interpretation of that mandate and the minimum that it requires. In this domain, as in so many others, courts have the capacity to differentiate a constitutional threshold, which ultimately is ours to determine, from the particular policy needs of a given moment, which lie within the General Assembly’s purview. The array of courts that have done precisely that in this arena suggests that our assessment in this regard is neither imprudent nor uncommon.

It is fair neither to the people of the Commonwealth nor to the General Assembly itself to expect that body to police its own fulfillment of its constitutional mandate. This is especially so in light of the many competing and not infrequently incompatible demands our legislators face to satisfy non-constitutional needs, appease dissatisfied constituents, and balance a limited budget in a way that will placate a majority of members in both chambers despite innumerable differences regarding policy and priority. Cf. Sweeney, 375 A.2d at 710 (quoting R. Brooke Jackson, The Political Question Doctrine, 44 U. Colo. L. Rev. 477, 501 (1974)) (“One does not think of [the legislature] as functionally equipped or designed to interpret the Constitution without review, nor under our system, does one wish to leave to [the legislature] unbridled authority to determine the constitutionality of its own acts.”). Judicial oversight must be commensurate with the priority reflected in the fact that for centuries our charter has featured some form of educational mandate. Otherwise, it is all but inevitable that the obligation to support and maintain a “thorough and efficient system of public education” will jostle on equal terms with non-constitutional considerations that the people deemed unworthy of embodying in their Constitution. We cannot avoid our responsibility to monitor the General Assembly’s efforts in service of its mandate and to measure those effects against the constitutional imperative, ensuring that non-constitutional considerations never prevail over that mandate.

Similarly, and for the reasons stated, we find colorable Petitioners’ allegation that the General Assembly imposes a classification whereunder distribution of state funds results in widespread deprivations in economically disadvantaged districts of the resources necessary to attain a constitutionally adequate education. Accordingly, the Commonwealth Court erred in determining that Petitioners’ equal protection claims are non-justiciable. Whether Petitioners’ equal protection claims are viewed as intertwined with their Education Clause claims or assessed independently, those claims are not subject to judicial abstention under the political question doctrine. It remains for Petitioners to substantiate and elucidate the classification at issue and to establish the nature of the right to education, if any, to determine what standard of review the lower court must employ to evaluate their challenge. But Petitioners are entitled to the opportunity to do so.

The Commonwealth Court’s order sustaining the Commonwealth’s preliminary objections is reversed. This case is remanded for further proceedings consistent with this Opinion.

Justices Todd, Donohue, Dougherty and Mundy join the opinion.

Justice Dougherty files a concurring opinion.

Chief Justice Saylor files a dissenting opinion.

Justice Baer files a dissenting opinion.

CONCURRING OPINION

JUSTICE DOUGHERTY

I join the majority opinion in concluding the matter before us is justiciable under the Baker factor analysis. I write separately to express my view that any time a party raises a colorable claim that a right guaranteed to the citizens of this Commonwealth by the Pennsylvania Constitution is being violated, such a claim always should be justiciable and analysis under the Baker factors is irrelevant because judicial restraint serves no purpose when constitutional rights are threatened or abridged. See Hugo L. Black, The Bill of Rights, 35 N.Y.U. L. Rev. 865, 870 (1960) (“[T]he judiciary was made independent because it has.. .the primary responsibility and duty of giving force and effect to constitutional liberties and limitations upon the executive and legislative branches.”).

The political question doctrine implicates the prudential concerns of judicial restraint. Robinson Twp. v Commonwealth, 623 Pa. 564, 83 A.3d 901, 917 (2013) (questions of justiciability involve “prudential concerns implicating courts’ self-imposed limitations”). See also L. Tribe, American Constitutional Law 79 (1978) (“Thus the political question doctrine, like other justi-ciability doctrines, at bottom reflects the mixture ' of constitutional interpretation and judicial discretion....”). The question of justiciability under the political question doctrine arises from a concern regarding the maintenance of the separation of powers. Consumer Party of Pa. v. Commonwealth, 510 Pa. 158, 507 A.2d 323, 332 (1986) abrogated on other grounds by Pennsylvanians Against Gambling Expansion v. Commonwealth, 583 Pa. 275, 877 A.2d 383 (2005) (“To preserve the delicate balance critical to a proper functioning of a tripartite system of government, this Court has exercised restraint to avoid an intrusion upon the prerogatives of a sister branch of government”). A court should refrain from resolving a dispute where doing so would involve the judicial branch in carrying out the functions properly delegated to the legislative or executive branches. Thornburgh v. Lewis, 504 Pa. 206, 470 A.2d 952, 956 (1983); see also Consumer Party, 507 A.2d at 333 (“it is appropriate to give due deference to a coequal branch of government as long as it is functioning within constitutional constraints ... ”). Nevertheless, the resolution of disputes involving the interpretation, of law is our constitutional duty. Robinson Twp., 83 A.3d at 928 (courts must fulfill role of enforcing constitutional limitations); Thornburgh, 470 A.2d at 956 (it is the courts’ constitutional duty to resolve disputes involving interpretation of the law). Further, it is the duty of the judicial branch to ensure that any constitutional right is not “impaired or destroyed by legislation.” Smyth v. Ames, 169 U.S. 466, 527-28, 18 S.Ct. 418, 42 L.Ed. 819 (1898); Zemprelli v. Daniels, 496 Pa. 247, 436 A.2d 1165, 1169 (1981) (“[I]t is the duty of the courts to. invalidate legislative action repugnant to the constitution.”). It would undermine our constitutionally mandated responsibilities to deliberately ignore a clear constitutional violation out of deference to a co-equal branch of government. Consumer Party, 507 A.2d at 333.

Appellants have challenged the current legislative framework for the financing and funding of the Commonwealth’s - public school system as constitutionally deficient on the basis that (1) the public school funding system does not meet the constitutionally mandated requirement to maintain a thorough and efficient system of public education as expressed in the Education Clause found in Article III, Section 14 of the Pennsylvania Constitution, and (2) the current funding system violates the right to equal protection guaranteed by Article III, Section 32 of the Pennsylvania Constitution (Equal Protection Clause).

' We have not been asked to decide whether, as a policy .matter, a particular funding method is better than another. Rather, we have been asked to determine whether the existing funding method passes constitutional muster. These constitutional challenges do not involve garden variety political questions. They entail grave social, economic, and moral implications and consequences. A proper public education is not a static concept and must change with the evolving world around us. Likewise, the provision and maintenance of a “thorough and efficient” public education system must also evolve to ensure the Commonwealth’s citizens are fully capable of competing socially, economically, scientifically, technologically and politically in today’s society. See, e.g., Claremont Sch. Dist. v. Governor, 138 N.H. 183, 635 A.2d 1375, 1381 (1993) (education necessary to meet duty to cherish public schools must “be adapted to the various crises of human affairs”), quoting McCulloch v. Maryland, 17 U.S. 316, 415, 4 Wheat. 316, 4 L.Ed. 579 (1819).

In my view, because the current challenge to the Commonwealth’s public education financing system involves uniquely compelling, issues which are not only of constitutional import for Pennsylvania’s students but also of paramount importance to the Commonwealth as a whole both now and in the future, this Court would be remiss.in its own constitutional obligations by abstaining from -deciding this constitutional challenge .based on any theory of judicial restraint. Consumer Party of Pa., 507 A.2d at 333 (“[W]hatever theory is employed, the legitimacy of the abstention is dependent upon the situation presented.”). See also Martin Redish, Judicial Review & the Political Question, 79 Nw. U. L. Rev. 1031, 1059 (1985) (asserting political question doctrine is problematic because it allows federal government or one of its branches to breach constitutional boundaries without check- of judicial review). Accordingly, Tbelieve the justiciability of questions related to our government’s compliance with its constitutional duties in this ever-evolving arena should not be subjected to-mere mechanical application of certain enumerated factors. See, e.g., William J. Brennan, State Constitutions & the Protection of Individual Rights, 90 Harv. L. Rev. 489, 490-92 (1977) (“state courts that rest their decisions wholly or even partly on state law need not apply federal principles of standing and justiciability that deny litigants access to the courts”); Helen Hershkoff, State Courts and the “Passive Virtues”: Rethinking the Judicial Function, 114 Harv. L. Rev. 1833, 1940 (2001) (“[Sjtate courts, because of their differing institutional and normative position, should not conform their rules of access to those that have developed under Article III [of the United States Constitution]. Instead, state systems should take an independent and pragmatic approach to judicial authority in order to facilitate and support their integral and vibrant role in state governance.”). Consequently, appellants should have the opportunity to seek a merits disposition of their claims.

DISSENTING OPINION

CHIEF JUSTICE SAYLOR

I respectfully dissent, as I would find that, per this Court’s prior decisions, resolution of the claim asserted under the Education Clause is entrusted to the political branches, and that the issue is, accordingly, non-justiciable. Notably, the parties do not ask that we overrule binding precedent in this regard.

Separately, I would conclude that the Petition fails to make out a viable cause of action under the equal protection requirement of the state charter.

Therefore, I would affirm the Commonwealth Court’s order sustaining the Respondents’ demurrers and dismissing the Petition.

I. Background

As the majority notes, several school districts, parents of children attending public schools, the Pennsylvania Association of Rural and Small Schools (“PARSS”), and the Pennsylvania State Conference of the NAACP (collectively, “Plaintiffs”) filed a petition for review in the nature of an action for declaratory and injunctive relief (the “Petition”) in the Commonwealth Court’s original jurisdiction. They named as respondents Pennsylvania’s Governor, Department of Education (the “Department”), acting Secretary of Education, and Board of Education (the “Board”) (collectively, the “Executive Defendants”), as well, as the Speaker of the Pennsylvania House and the President Pro Tempore of the Pennsylvania Senate (the “Legislative Defendants”).

The majority sets out the background to this litigation in some detail. To summarize, according to the Petition Pennsylvania school districts are supported by a combination of local, state, and federal funds, with local sources contributing the greatest portion. In one recent fiscal year, for example, local sources provided 53% of public-education funding, state appropriations accounted for 34%, and the remaining 13% was furnished by the federal government. Because local school tax revenues depend on the total value of the real estate in a .school district, wealthier districts can raise more, money locally than poorer ones. The state contribution is calculated using a form.ula designed to moderate this disparity by providing, more money to poor districts than to wealthy ones. Significant discrepancies in per-pupil spending nonetheless persist due to substantial wealth disparities among school districts and the overall scheme’s heavy reliance on local taxation, even though many less-affluent districts expend greater tax effort (i&, impose higher tax rates) than wealthier ones.

In 2006 the Legislature directed the Board to determine the cost of providing students with the basic instruction necessary to achieve baseline educational standards as set forth by the state. The resulting costing-out study, conducted by a private contractor with Board oversight, estimated that the per-student cost to attain these mandates was approximately $11,900, whereas the average amount being spent was about $9,500. The aggregate cost to meet the standards was determined to be $21.6 billion — 25% more than the amount being spent. The study also found that 94% of Pennsylvania’s 500 school districts were spending less than their costing-out estimate and that the poorest 20% of school districts needed to increase spending by 38%, whereas the wealthiest 20% of school districts only needed to increase spending by 7%.

To address these shortfalls, the General Assembly passed Act 61 of 2008, which increased funding for basic education and implemented a new formula for determining the amount of state funding to be disbursed to each school district. Act 61 also increased monies for basic education by $275 million in 2008 and was intended to be the first step of a six-year plan to assist school distiicts in meeting the state’s adequacy objectives. The formula was used in 2009 and 2010 to determine both the aggregate state appropriation and its distribution among school districts. Overall state education funding increased by $655 million between 2008 and 2010. To supply this increase, the Commonwealth began relying on federal stimulus dollars available under the American Recovery and Reinvestment Act of 2009, and it used these funds to replace state-raised revenue that had previously been appropriated to education.

The stimulus money expired in 2011. By that time the state had substituted $480 million in federal funds for state revenues targeted to basic education. By June 2011, Pennsylvania faced the prospect of finding a replacement for approximately $1 billion in federal stimulus monies in its overall fiscal-year 2011-12 budget. Instead of supplying $1 billion in new state funds, however, the Legislature implemented $860 million in budget cuts which encompassed reductions for programs supporting public education. At this juncture, Act 61’s multi-year funding formula was abandoned in favor of a formula to be decided upon annually going forward. Although later spending increases ameliorated some of the 2011 budget cuts, the present budget reflects a $580-million reduction in state education spending as compared to the period ending in June 2011, which is well below the levels reflected in the costing-out study. At the same time, school districts’ ability to raise new local taxes to fill the void has been limited under the Taxpayer Relief Act of 2006. Pursuant to that legislation, school districts are generally precluded from raising real-estate taxes beyond a cost-of-living index as calculated by the Department. Because the index is expressed as a percentage, such potential increases are lower in low-wealth districts than in high-wealth districts.

Meanwhile, beginning in 1999 and pursuant to legislative authorization, the Board promulgated regulations setting forth, and ultimately expanding upon, statewide academic standards which specify what schoolchildren should be taught in a variety of subjects. Additionally, statewide standardized testing was established in the form of the Pennsylvania System of School Assessment (“PSSA”) and the Keystone exams. Although PSSA and other standardized exams had existed before 1999, the 1999 changes made the standards more concrete. Later, in 2014, the Board implemented the Pennsylvania Common Core Standards, which replaced the academic standards in math, English, language arts, and literacy, but left in place the pre-existing standards for other subject areas. The standards are not merely aspirational, as students may have to retake exams they fail as a requirement for graduation, and school districts, as well as their teachers and administrators, are evaluated on whether students are meeting state standards.

As a result, the gap between state adequacy targets and academic achievement in the subject school districts (ie., the plaintiff school districts, PARSS member districts, and districts containing schools attended by children of individual plaintiffs) has widened. In particular, many students in these low-wealth districts are unable to meet state proficiency standards on the Keystone and PSSA tests, and some districts have eliminated courses and programs that would otherwise have helped improve student performance on those exams. Also, some pupils in poor districts require higher-than-average funding due to conditions associated with poverty or the fact that English is not their first language. School districts with significant monetary shortfalls, moreover, have insufficient and undertrained staff, as well as inferior equipment, facilities, and materials. In these districts, there is often inadequate pre-kindergarten program funding, meaning that the district must choose between spending less or using general operating funds to provide such pre-kindergar-ten programs.

Based on these allegations, the Petition set forth two counts. In Count I, Plaintiffs claimed Defendants had violated their duties under the Education Clause, which requires that the General Assembly “provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.” PA. Const, art. Ill, § 14. In this regard, they alleged that Defendants had defined the content of an adequate education — ie., one that will “serve the needs of the Commonwealth” — via the promulgation of academic standards assessed pursuant to the PSSA and Keystone exams. They added that the state Common Core standards “set forth a prescribed course of study and a uniform educational progression from grade to grade, and form a core, fundamental element of the Commonwealth’s current system of public education.” Petition ¶303. Plaintiffs averred that Defendants' failed to provide the school districts in question with enough funding to ensure that all students have an opportunity to receive an adequate education — where adequacy is measured by whether the students are prepared to “meet state academic standards” and to achieve “civic, economic, and social success” beyond school. Id. ¶304. Plaintiffs maintained that the current levels and allocation of school funding “are irrational, arbitrary, and not reasonably calculated to ensure that all Pennsylvania schoolchildren have access to an adequate education[.]” Id. ¶305.

In Count II, Plaintiffs relied on Pennsylvania’s Equal Protection Clause as a basis for relief. See PA. Const, art. Ill, § 32. They asserted that education is a fundamental right and, as a corollary, the state government has an obligation to ensure all -students have an equal opportunity to obtain an adequate education. Thus, Plaintiffs alleged that the state charter prohibits the Legislative Defendants from enacting laws that benefit a select few. In this respect, Plaintiffs contended' that many funding methodologies exist which would support the state’s interest in preserving local control of public, education without discriminating against students, in low-wealth school districts. Plaintiffs alleged that Defendants had violated Section 32 by adopting a school funding program that discriminates against students living in such districts by denying them an equal opportunity to obtain an adequate education. See id. ¶¶308-311,

In terms of relief, Plaintiffs asked the court to declare that: public education is a fundamental right of all schoolchildren in Pennsylvania; the Education Clause imposes on Defendants an obligation to adopt a school-financing arrangement which (i) is reasonably calculated to ensure — and does ensure — that all schoolchildren can obtain an education which enables them to meet state academic standards and participate meaningfully in society, and (ii) does not discriminate against students who live in low-income, low-property-value school districts; the, present arrangement violates the Education, Clause as well as Plaintiffs’ rights under the Equal Protection Clause by giving students in high-wealth districts an opportunity to attain an adequate education while denying the same opportunity to students in low-wealth districts; and no compelling state interest justifies the existing funding disparity between those'two categories of school districts. See id. ¶¶312-19. ■

Plaintiffs also requested injunctive relief, specifically, permanent injunctions directing Respondents to develop and maintain a system which provides an equal opportunity to all students to obtain an education meeting academic standards and societal participation. Finally, Plaintiffs asked the Commonwealth Court to retain jurisdiction to ensure Defendants’ ultimate compliance with the contemplated injunctions. See id. ¶¶320-24.

The Legislative and Executive Defendants each filed preliminary objections in the nature of a demurrer. See Pa.R.C.P. No. 1028(a)(4). Defendants averred primarily that Plaintiffs’ claims present non-justiciable political questions. They maintained, in this respect, that there are no judicially manageable standards for granting relief. Defendants also argued that Plaintiffs failed to state a claim for which relief may be granted because the existing statutory scheme rationally serves the state’s interest, per the Education Clause, in maintaining and supporting a thorough and efficient system of public education. As well, Defendants suggested that Plaintiffs’' claims under the Equal Protection Clause were legally insufficient because education is not a fundamental right subject to strict scrutiny, and the present funding system rationally serves the government’s interest in preserving loc'al control over public education. Finally, Defendants averred that Plaintiffs’ causes of action were barred by sovereign immunity — to the extent they sought mandatory injunctive relief — as well as the separation of powers doctrine insofar as they were asking the judicial branch to compel action by the General Assembly and to subject it to ongoing court supervision.

In a unanimous, published decision, the Commonwealth Court sustained the preliminary objections and dismissed the Petition on the grounds that, pursuant to this Court’s precedent, the claims under both the Education and Equal Protection Clauses raised non-justiciable political questions. See William Penn Sch. Dist. v. Pa. Dep’t of Educ., 114 A.3d 456, 464 & n.15 (Pa. Cmwlth. 2015) (en banc).

Initially, the Commonwealth Court observed'that this Court has referenced the considerations listed in Baker v. Carr, 369 U.S. 186, 82 S.Ct. 691, 7 L.Ed.2d 663 (1962), to ascertain whether the political question doctrine counsels in favor of abstention in a given case. See William Penn Sch. Dist., 114 A.3d at 462 (citing Sweeney v. Tucker, 473 Pa. 493, 375 A.2d 698 (1977), and quoting Robinson Twp. v. Commonwealth, 623 Pa. 564, 608-09, 83 A.3d 901, 928 (2013)). Rather than analyzing the Baker factors, however, the Commonwealth. Court stated that the, justiciability issue was decided in Marrero v. Commonwealth, 559 Pa. 14, 739 A.2d 110 (1999) (“Marrero IF), where this Court held that the political question doctrine precluded review of an Education Clause challenge to the state’s public school funding scheme, and Danson v. Casey, 484 Pa. 415, 399 A.2d 360 (1979), in which the Court determined that claims under the Education and Equal Protection Clauses failed to state a justiciable cause of action. The Commonwealth Court rejected Plaintiffs’ attempt to distinguish Marrero II based on subsequently-adopted education standards and assessments, reasoning that such factors may establish policy-related benchmarks, but they cannot supply courts with judicially manageable standards to determine whether the Legislature has fulfilled its constitutional duties. See William Penn Sch. Dist., 114 A.3d at 463.

.Plaintiffs appealed, primarily questioning whether the political question doctrine should be understood to preclude a. merits disposition of a petition which: alleges that the state government is in violation of the Education Clause, because its school-funding scheme “bears no relationship” to the cost of preparing students to meet state academic standards; and avers, as well, that the existing funding system violates the Equal Protection Clause due’ to “gross and irrational disparities” in funding between low-wealth and high-wealth school districts. Brief for Appellants at 2.

This Court has exclusive appellate jurisdiction. See 42 Pa.C.S. § 723(a). We undertake de novo review, assessing whether the law says with certainty that relief is unavailable. See Bruno v. Erie Ins. Co., 630 Pa. 79, 91, 106 A.3d 48, 56 (2014).

II. The Education Clause Claim

Plaintiffs contend that the Commonwealth’Court’s decision should be reversed because this Court has never adopted a per se rule that Education Clause claims are noh-justiciáble, and hence, the Commonwealth Court erred by interpreting Marrero II as establishing such a rule. They suggest that the Baker factors do not support abstention in this case, and even if they did, any separation-of-powers concerns are overridden by the need to vindicate what they describe as the fundamental right of schoolchildren to receive an adequate public education. See Brief for Appellants at 27, 43-44.

As to the Baker factors specifically, Plaintiffs make three arguments. Regarding the first factor — whether there is a “textually demonstrable constitutional commitment of the issue to a coordinate political department” — Plaintiffs assert that the wording of the Education Clause does not authorize the General Assembly to monitor the propriety of its own education-funding scheme. Plaintiffs also posit that the history underlying the Clause does not support such self-monitoring because its language was developed in response to public discontent with the lack of state support for schools in poor communities, which was having an adverse effect on the quality of education delivered in those geographical areas. See id. at 29-32.

Addressing the second Baker factor— whether there are “judicially manageable standards for resolving” the constitutional challenge — Plaintiffs argue that, unlike when Marrero II was decided, academic criteria and assessments now supply judicial standards to determine whether education funding levels bear a reasonable relation to satisfying the Education Clause’s dictates. They note that other states have used similar educational benchmarks in determining whether their respective legislatures have complied with them constitutional duties. Acknowledging that a small number of underperforming school districts could reflect local mismanagement or ineffective teachers, Plaintiffs reason that the systemic failure of Pennsylvania’s school districts to satisfy established academic criteria proves that the current funding scheme violates the Education Clause. See id. at 14-15, 36 (providing student pass-rates on the Keystone and PSSA exams). Plaintiffs also reference the costing-out study as evidence that the cost of providing each student with an opportunity to meet state standards is now measurable. See id. at 32-39.

With respect to the third Baker factor— whether it is “impossibl[e]” for the court to decide the issue “without an initial policy determination of a kind clearly for nonjudicial discretion” — Plaintiffs argue that resolving their claim would not require this Court to make a policy judgment as to what constitutes an adequate education since Defendants have already done so by adopting the referenced standards and assessments. Further, they advance that the type of declaration they are seeking would not immerse the judiciary in the minutiae of educational policy choices such as class sizes or textbook requirements. Rather, in Plaintiffs’ view, since they are seeking a declaratory judgment that Defendants have failed to meet their obligations under the Education Clause, the Court can simply decide whether the public school funding scheme Defendants have adopted is constitutional — an inherently judicial task. See id. at 39-41.

Insofar as Plaintiffs are also seeking injunctive relief, they propose that this Court follow the lead of other state courts which have imposed deadlines for compliance, as well as consequences, such as large daily fines levied against the legislative body for failure to comply in a timely manner, and required ongoing judicial monitoring of that body. They contend that, in a number of cases, the judicial finding of a constitutional violation has itself motivated the political branches to formulate and implement a solution within a reasonable timeframe. See id. at 41-43.

In response, the Executive Defendants reference pronouncements from the United States Supreme Court and this Court reflecting that the judicial branch is institutionally ill-suited to formulate or evaluate policy choices relating to local public schools, as it is unable to gauge what constitutes an adequate education or- what funds are- necessary to meet educational goals. See Brief for Executive Appellees at 17-20 (quoting, inter alia, San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1, 41, 93 S.Ct. 1278, 1301, 36 L.Ed.2d 16 (1973), and Wilson v. Sch. Dist. of Phila., 328 Pa. 225, 236-37, 195 A. 90, 97 (1937)). Based on Danson and Marrero II, they reason, more particularly, that issues implicating the design and funding of the public education system are committed solely to the General Assembly. The Executive Defendants observe that, unlike some of the amici, Plaintiffs do not ask that Marrero II be reconsidered, but rather, attempt to distinguish it based on educational assessments and standards adopted after 1999. They therefore posit that reconsidering Marrero II is not before this Court, as arguments made by amici do not comprise party arguments. See id. at-20-22.

With regard to Plaintiffs’ contention that this case may be distinguished from Danson and Marrero II because the latest educational assessments and the monetary amounts in the costing-out study can serve as judicially manageable standards, the Executive Defendants note that, as reflected in administrative regulations, statewide assessments and standards have existed since the late 1960s, well before Danson and Marrero II. According to the Executive Defendants, such items are imbued with political judgments subject to change by future policymakers — and this includes the costing-out study, which incorporates policy choices regarding acceptable proficiency levels in various academic subjects. See id. at 25 (quoting Hancock v. Comm’r of Educ., 443 Mass. 428, 822 N.E.2d 1134, 1136 (2005) (plurality) (suggesting that costing-out studies are “rife with policy choices that are properly the Legislature’s domain”)). ■

More generally, the Executive Defendants reason that utilizing the most recent standards issued by the political branches as judicial guides would be unmanageable and would bind future legislators to current' legislative thinking — contrary to the precept that the “essence” of the Education Clause is to enable free experimentation by the Legislature. Teachers’ Tenure Act Cases, 329 Pa. 213, 224, 197 A. 344, 352 (1938); Danson, 484 Pa. at 426, 399 A.2d at 366. They state that, in view of Plaintiffs’ request for continuing court oversight, a failure to abstain would cause courts to supervise ever-changing educational standards, thus entangling courts with policy matters such as exam cut-off scores and acceptable district-wide pass rates. See Brief for Executive Appellees at 23-29. Along these lines, the Executive Defendants contend that courts which have used educational assessments as judicial guides have become mired in education policy and have extended their reach beyond the constitutionality of public-school funding schemes. See id. at 29-31 (discussing the experiences of courts in California, New Jersey, New Hampshire, Kansas, and Nebraska).

Alternatively, the Executive Defendants argue that thp Petition fails, to state a claim upon which relief can be granted,, as there is no reasonable argument that the Commonwealth’s public education scheme does not bear a reasonable relation to complying with.the Education Clause. See id. at 37-39. They also contend that, because Plaintiffs seek a mandatory injunction compelling a new public education framework, their suit is barred under the doctrine of sovereign immunity. See id. at 39-41. Finally; the Executive Defendants- assert that granting Plaintiffs’ request to compel the General Assembly to enact specific legislation would violate, the separation-of-powers doctrine. See id. at 41-42.

The Legislative Defendants add that the crux of Plaintiffs’ . complaint — le., .that Pennsylvania’s public-education funding system is irrational and underfunded, .and discriminates against certain students — is the same claim that Danson and Marrero II rejected. They view Danson and Marre-ro II, together, as standing for tjie position that, so long as the established funding scheme bears a reasonable relation to the provision of a thorough and efficient system of education, courts may not intrude on that scheme. Because Marrero II, which built upon Danson, concluded that a reasonable relation did, in fact, exist by virtue of the present system of’ funding schools via a combination of local taxés, state appropriations, and federal grants, the Legislativé Branch Defendants contend Plaintiffs raise no new issue to consider.

The Legislative Defendants advance, in this regard, that the extra-jurisdictional judicial decisions which Plaintiffs reference are immaterial since Danson and Marrero II are dispositive in relation to Pennsylvania’s system. To the degree Plaintiffs rely on such decisions to imply Danson and Marrero II should be reconsidered, the Legislative Defendants submit that the doctrine of stare decisis weighs against reconsideration. They indicate this is true generally, and in this case particularly so, since various education stakeholders have acted in reliance on Danson and Marrero II, and these actors would'only have a voice concerning contemplated changes in a legislative forum. See Brief for Legislative Appellees at 10-27. Regardless, the Legislative Defendants maintain, in recent years a number of appellate courts in other jurisdictions have issued holdings in line with Marrero II because, although the text and history, of their constitutional provisions may vary, they have developed a “keen awareness of the perils of supplanting [the] legislative process with judicial activism.” Id. at 23. . .

Finally, the Legislative Defendants refute any suggestion that 'this Court has altered its analysis of political-question claims, asserting the Baker factors remain the central focus of such claims, and the circumstance that this Court has declined to abstain under the political-question doctrine in other contexts bears little relevance to the continuing vitality of Danson and Marrero II. They note that, except with' respect to judicial funding issues, Pennsylvania courts have shown a strong predisposition against “second guessing” the General Assembly’s budgetary decisions. Id. at 21 (citing Pa. Envtl. Def. Found. v. Commonwealth, 108 A.3d 140, 166 (Pa. Cmwlth. 2015)).

After oral argument Governor Wolf filed a supplemental brief addressing recent legislation, namely, the Act of June 1, 2016, P.L. 252, No. 35 (“Act 35”), which added provisions to the Public School Code of 1949, see 24 P.S. §§ 1-124, 25-2502.53, 25-2502.54, and appropriated- supplemental funds for basic education. According to the Governor, Act- 35 works a significant change to the school-funding landscape because school districts will now receive from the state both a basic subsidy and an additional substantial grant pursuant to a “fair-funding formula” which accounts for “district-specific factors, such as local taxing/revenue-generating capacity, student population size and density, and specific student-related indices, including the number of children ... who live in poverty.” Supplemental Brief for Governor Wolf at 3. He represents that every new dollar in state education funding going forward will be distributed per the fair-funding formula. The Governor concludes that Act 35 illustrates that appropriating and distributing education funds involves “inherently and necessarily political questions that are beyond the jurisdiction of this Court,” and, as such, Plaintiffs seek relief which would intrude on the prerogatives of the government’s political branches. Id. at 5.

In a responsive brief, Plaintiffs agree that the fair-funding formula distributes funds equitably, but they contend that the percentage of state education money subject to the formula is too small to remediate the underlying circumstance that public school funding is overly reliant on property taxes — with the result that -such funding remains inequitable and inadequate even in the wake of Act 35. Overall, Plaintiffs argue that the Governor’s advocacy shows that the needs of each school district are, in fact, capable of objective determination (thus undercutting Defendants’ non-justiciability argument), and that the issue of whether Act 35 provides for an adequate education for the state’s schoolchildren is fundamentally a question of fact to be resolved at trial.

“Ordinarily, the exercise of the judiciary’s power to review the constitutionality of legislative action does not offend the principle of separation of powers,” Sweeney, 473 Pa. at 508, 375 A.2d at 705 (citing Marbury v. Madison, 5 U.S. (1 Cranch) 137, 2 L.Ed. 60 (1803)), inasmuch as it is “emphatically the province and duty of the judicial department to say what the law is.” Marbury, 5 U.S. (1 Cranch) at 177. “Sometimes, however, the law is that the judicial department has no business entertaining the claim of unlawfulness — because the question is entrusted to one of the political branches!)]” Vieth v. Jubelirer, 541 U.S. 267, 277, 124 S.Ct. 1769, 1776, 158 L.Ed.2d 546 (2004) (plurality).

Pennsylvania courts have historically been reluctant to intervene when faced with complaints alleging the General Assembly has failed to fulfill its Education Clause obligations. Abstention as to questions concerning the adequacy of public education generally dates as far back as the mid-1800s. The concept was invoked relative to the earlier version of the Education Clause which appeared in the Constitutions of 1790 and 1838 and directed that “[t]he legislature shall, as soon as conveniently may be, provide by law for the establishment of schools throughout the state, in such manner that the poor may be taught gratis.” PA. Const, art VII, § 1 (1790, 1838). In Commonwealth v. Hartman, 17 Pa. (5 Harris) 118 (1851), the Court noted that the Constitution permitted the Legislature to “provide for a system of general education in any way which they, in .their own wisdom, may think best,” and added that even if an education-related statute was “unjust in its operation,” “the remedy lies, not in an appeal to the judiciary, but to the people, who must apply the corrective themselves[.]” Id. at 119, quoted in Marrero v. Commonwealth, 709 A.2d 956, 966 n.21 (Pa. Cmwlth. 1998) (“Marrero I”), aff'd, 559 Pa. 14, 739 A.2d 110 (1999).

With regard to the 1874 Education Clause — the first version to require support for a “thorough and efficient” system, see supra note 3 — litigation- initially focused on whether school board decisions were judicially reviewable, with the Court concluding that they were not, at least absent a gross abuse of discretion such as an unexcused failure to provide for any public education. See Nicklas v. Kaltenbaugh, 146 Pa. 212, 220, 23 A. 316, 316 (1892); see also Roth v. Marshall, 158 Pa. 272, 273-74, 27 A. 945, 945 (1893) (expressing that a school board’s exercise of its discretion is generally a political matter to be remedied, if necessary, at the ballot box). See generally Wilson, 328 Pa. at 236-37, 195 A. at 97 (elaborating on these observations).

Later, in Teachers’ Tenure Act, several school districts challenged the validity of the Teachers’ Tenure Act of 1937 as impairing, in violation of the Contracts Clause, the obligations of their existing contracts with professional school employees. This Court found that the Education Clause saved the statute because the Clause embodies the concept that public-school teacher contracts are impliedly qualified by the possibility of future legislative modification. See Teachers’ Tenure Act, 329 Pa. at 228, 197 A. at 354. In reaching this holding, the Court discussed the nature of public education in Pennsylvania and the judiciary’s role in evaluating statewide enactments (as opposed to local school board decisions) under the • Education Clause. It explained initially that the electorate, in approving the Clause, had given an affirmative mandate to the Legislature which the latter had no discretion to ignore. The Court then developed that, by their nature, educational methodologies evolve over time, and any given General Assembly lacks the power to constrain future legislatures in matters of educational policy:

[Everything directly related to the maintenance of a ‘thorough and efficient system of public schools,’ must at all times be subject to future legislative control. One Legislature cannot bind the hands of a subsequent one; otherwise we will not have a thorough and efficient system of public schools.

Id. at 225, 197 A. at 352.

Thus, in light of the need for “successive Legislatures to adopt a changing program to keep abreast of educational advances,” id. at 224, 197 A. at 352, the Court reasoned that, rather than inquiring into the wisdom or expediency of existing policy in matters of public education, the judiciary should limit itself to assessing whether the Commonwealth’s education laws bear a “reasonable relation” to the purpose of the Education Clause — namely, providing for a thorough and efficient system of public schools — and whether the “fruits or effects” of such laws might limit the ability of future legislatures to modify the school system in an effort to make it thorough and efficient. Id.

With the above as background, this Court first addressed a challenge brought directly pursuant to the Education Clause in Danson. There, the Philadelphia School District and several parents commenced an action against state education officials, alleging the district was underfunded to the point it would not be able to offer a “normal” educational program to its students. They argued the statutory formula for state-level educational funding was unconstitutional and that no state money should be distributed until the formula was revised to ensure the school district received the funds it needed to operate its schools. More broadly, the plaintiffs suggested that the state school-financing system failed to provide Philadelphia’s schoolchildren with a thorough and efficient education and denied them equal educational opportunities solely due to their residence in Philadelphia. See Danson, 484 Pa. at 420, 399 A.2d at 363.

The Danson Court responded by' emphasizing that the Education Clause contemplates that future legislatures must always be free to experiment and adjust the state’s public-education system, see id. at 426, 399 A.2d at 366 (describing this as “the very essence” of the Clause (quoting Teachers’ Tenure Act, 329 Pa. at 224, 197 A. at 352)), and thus, it would be improper for a reviewing court to bind such legislatures to “a present judicial view of a constitutionally required ‘normal’ program of educational services.” Id. Danson added that, even if the Court were inclined to define a thorough and efficient education, the only judicially-manageable standard would be that the same dollar amount be expended on each student in the state. This, however, would read into the Education Clause a uniformity component which the framers expressly rejected in favor of local variation and control according to the needs of particular school districts, as well as .the right ,of localities to raise additional taxes to expand their school offerings. See id. at 427, 399 A.2d at 366-67. See generally Rodriguez, 411 U.S. at 49-50, 93 S.Ct. at 1305 (expounding on the historical importance of local control and noting that it promotes “experimentation, innovation, and a healthy competition for educational excellence”). The Court thus held that

.the General Assembly has fulfilled its constitutional duty to the public school students of Philadelphia. The Legislature has enacted a financing scheme reasonably related to maintenance and support of a system of public education -in the Commonwealth of Pennsylvania. The framework is neutral with regard to the School District of Philadelphia and provides it with its fair share of state subsidy funds.

Danson, 484 Pa. at 427-28, 399 A.2d at 367. Evidently applying the above reasonable-relation standard as a kind of minimal check as to legislative purpose (discussed in more detail below), Damon concluded that the plaintiffs had otherwise “failed to state a justiciable cause of action.” Id. at 420, 399 A.2d at 363.

Twenty years later in Marrero II, another ' group of Philadelphia plaintiffs, again including the Philadelphia School District, lodged a similar complaint, asserting that the state had violated the Education Clause by failing to provide enough funding to the district. They argued that, due to its urban setting, the district was already financially overburdened and it was required to educate a disproportionate number of students living in poverty— students whose unique needs were alleged to require additional -expenditures above and beyond the statewide norm. The plaintiffs claimed that the school district had a weak tax base which it could not rely on to generate the extra monies needed for its students, and thus, the General Assembly should be directed pursuant to the Education Clause to appropriate more funding to the district.

Drawing on Danson, Marrero II expounded that the Education Clause is limited in scope in that it only requires the Legislature to provide for a thorough and efficient system of public education, but it does not give students an individual right to a particular level or quality of education. See Marrero II, 559 Pa. at 17, 739 A.2d at 112. Marrero II also reiterated that: successive legislatures must remain at liberty to alter educational policy; the only judicially-manageable standard would be to require the same dollar expenditure per student (which would improperly import into the Education Clause , a uniformity mandate); the deferential reasonable-relation standard governs such challenges; and courts should refrain from involvement as long as that standard is met. See id. at 17-19, 739 A.2d at 112-13. Marrero II found that-the-standard was met because the General Assembly had enacted a number of laws governing the funding and operation of the public school system throughout the Commonwealth, including in Philadelphia. See id. at 20, 739 A.2d at 113.

As to the political question doctrine, Marrero II observed that the Commonwealth Court had held that the first three Baker factors all required abstention. In particular, the' Commonwealth Court determined' that the Education Clause places sole responsibility for maintaining the state’s public school system in the hands of the Legislature and, as such, questions relating to what constitutes an “adequate” education or how much funding is needed are exclusively within the General Assembly’s purview and “are not subject to intervention by the judicial branch[.-]” Marrero I, 709 A.2d at 965-66. As a consequence, the court found that “prominent on the surface of the case” was a “textually demonstrable constitutional commitment of the issue to” the Assembly, there was a “lack of judicially manageable standards for resolving” the claims, and it would be impossible to resolve them “without making an initial policy determination of a kind Which is clearly of legislative, and not judicial, discretion." Id. at 966 (citations omitted). .

Notably, this Court approved and, in effect, adopted these determinations as its own. See Marrero II, 559 Pa. at 19-20, 739 A.2d at 113-14 (stating the Commonwealth Court’s reasoning “discloses no error, but rather a conscientious adherence to precedent”). In concluding, Marrero II quoted with approval from Marrero I as follows:

Thus, this court will riot inquire into the reason, wisdom, or expediency of the legislative policy with regard to education, nor any matters relating to legislative determinations of school policy or the scope of educational activity. In short, as the [Pennsylvania] Supreme Court was unable to judicially define what constitutes a “normal program of educational services” in Danson, this court is likewise unable to judicially define what constitutes an “adequate” education or what funds are “adequate” to support such a program. These are matters which are exclusively within the •purview of the General Assembly’s powers, and they are not subject to intervention by the judicial branch ~of our government.

Marrero II, 559 Pa. at 20, 739 A.2d at 113-14 (quoting Marrero I, 709 A.2d at 965-66) (citation omitted, emphasis added); see also Pa. Sch. Bds. Ass’n v. Commonwealth Ass’n of Sch. Adm’rs, 569 Pa. 436, 461-62, 805 A.2d 476, 490-91 (2002) (rejecting an Education Clause challenge to a .statute giving certain school administrators collective-bargaining rights because determining whether the statute would result in a failure to provide for a thorough and efficient system of education involved education-policy questions beyond the realm of the judiciary); Reichley v. N. Penn Sch. Dist., 533 Pa. 519, 529, 626 A.2d 123, 129 (1993) (same as to an Education Clause challenge to a Public Employee Relations Act provision allowing labor strikes by teachers and other professional school employees). See generally Ehret v. Sch. Dist. of Kulpmont, 333 Pa. 518, 525, 5 A.2d 188, 192 (1939) (noting that under the Education Clause the Legislature is “empowered to determine what is ‘efficient’ in- school management”). But cf. Sch. Dist. of Phila. v. Twer, 498 Pa. 429, 435, 447 A.2d 222, 225 (1982) (clarifying that courts are competent to review administrative interpretations of school-related legislation within the context of the Assembly’s Education Clause responsibilities).

A. The “thorough and efficient” requirement and justiciability

As can be seen from the brief history given above, the justiciability of claims asserting that the legislative scheme governing the amount and distribution of state public-education funding works an Education Clause violation is now well-trodden territory in Pennsylvania. There have been repeated pronouncements by this Court over eight decades that future Legislatures cannot be bound by a present judicial view of what constitutes a thorough and efficient system of public education. Accord 78 C.J.S. Schs. & Sch. Dists. § 6 (“[A school] system may'be changed, or one system substituted for another, as often as the legislature deems it necessary or expedient so to do,”). When the Legislature adopts statewide academic standards, it bases its decisions on intensive scientific, fiscal, and practical considerations, as well as evolving political values. Because the General Assembly is institutionally better suited to understand and respond to those concerns than the judiciary, academic standards, which necessarily must change over time, do not provide a judicially manageable mechanism for oversight. In light of the reasoning and holdings reflected in Danson, Marrero, Pennsylvania School Boards Association, and Reichley, moreover, it is now established that Education Clause claims generally raise political questions to be resolved through the political process.

Nevertheless, Plaintiffs seek to distinguish Danson and Marrero II primarily on the basis that those decisions only found the issue before the Court non-justi-ciable under the specific facts alleged, whereas here, the Baker factors militate in favor of merits review since standards have now emerged — in the form 'of statewide academic performance goals and the costing-out study — by which to measure whether the General Assembly has fulfilled its duties under the Education Clause. Thus, as noted, Plaintiffs argue that the components of an adequate education have now been supplied legislatively and administratively, and that the costing-out study indicates the cost of providing all schoolchildren in Pennsylvania with a constitutionally-adequate education.

Initially, I would find Plaintiffs’ reading of Danson and Marrero II unduly narrow. As reflected in the above-quoted passage, Marrero II clarified that the judiciary is not in a position to determine what constitutes an “adequate” education or how much money is needed to support a system capable of giving all schoolchildren in the state an opportunity to obtain one; these issues are within the exclusive province of the legislative branch. See Marrero II, 559 Pa. at 20, 739 A.2d at 113-14. As for Danson, that decision emphasized that, even if the judiciary could foresee future needs and “define the specific components of a thorough and efficient education,” it would lack judicially-manageable standards to enforce legislative compliance because the only available measurement would be the dollar amount spent per pupil, whereas the education which students receive depends on other factors, including the way money is spent and the manner in which the purchased resources are utilized. Danson, 484 Pa. at 427, 399 A.2d at 366 (internal quotation marks omitted).

To the extent Plaintiffs’ position rests on the concept that legislative and administrative action in setting academic goals, implementing standardized tests, and commissioning a costing-out study can operate to create judicially-enforceable constitutional standards, I find such a premise problematic. The difficulty becomes apparent when one considers how these measures may translate into a judicial litmus capable of determining whether the Legislature’s funding scheme, at a particular point in time, complies with the Education Clause. One possibility would be to consti-tutionalize the academic standards in place when the Petition was filed. This would mean overlaying the PSSA,. Keystone, and Common Core targets onto the Education Clause as part of its substantive mandate. Such a holding would be in tension with the precept that future legislatures are always free to adopt new educational methodologies and alter their conception of what constitutes a thorough and efficient system of education. For their part, Petitioners clarify that this is not what they are requesting. See Reply Brief for Appellants at 12.

Another option — the one Plaintiffs do propose, see id. at 12-14 — is to conclude that, whenever the- General Assembly and relevant state administrative bodies establish academic standards and associated assessment vehicles, those items reflect such entities’ “current pronouncement of what a thorough and efficient system of public education should teach students[.]” Id. at 12 (internal quotation marks omitted). While this is certainly more plausible than the first option, judicial enforcement on such terms has multiple conceptual difficulties. It would read too much into legislative and administrative actions. Absent some indication by the political branches, it cannot be assumed that they view such items as reflecting the constitutional minimum (as opposed to, for example, a system significantly exceeding that minimum). Thus, a holding along these lines would ascribe constitutional significance to educational policy decisions made at a specific time. But cf. Idaho Schs. for Equal Educ. Opportunity v. Evans, 123 Idaho 573, 850 P.2d 724, 734 (1993) (upon examination of educational standards promulgated by the executive branch of the state government, holding that the standards’ requirements as to textbooks, facilities, transportation, and instructional programs “are consistent with our view of thoroughness”).

Neither the Education Clause, nor any other constitutional provision, indicates that standards set forth legislatively or administratively are to be viewed as subsuming a constitutional dimension. The Clause states in full: “The General Assembly shall provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.” PA. Const, art. Ill, § 14. This may be compared with other state charters, some of which expressly constitutionalize standards set forth by law or regulation. See Or. Const, art. VIII, § 8(1) (“The Legislative Assembly shall appropriate in each biennium- a sum of money sufficient to ensure that the state’s system of public education .meets quality goals established by law .” (emphasis added)); Va. Const, art. VIII, § 1, 2 (requiring the legislature to maintain a system of free schools with “high quality” educational programs, and specifying that quality standards are to be “determined and 'prescribed from time to time by the Board of Education, subject to revision only by the General Assembly”); cf Miss. Const, art. VIII, § 201 (directing that the legislature provide for the maintenance of “free .public schools upon such conditions and limitations as the Legislature may prescribe”).

Unlike these provisions, our own Education Clause does not tether the required funding scheme to legislative or administrative “quality goals,” “conditions,” or “quality standards,” nor does it otherwisé contain descriptors beyond the adjectives “thorough” and “efficient.” See Neb. Coal. for Educ. Equity & Adequacy v. Heineman, 273 Neb. 531, 731 N.W.2d 164, 180 (2007) (interpreting the “paucity of standards” in Nebraska’s education clause as reflecting the framers’ “intent to commit the determination of adequate school funding solely to the Legislature’s discretion, greater resources, and expertise”). Thus, although some other jurisdictions have relied on legislatively-devised benchmarks to provide constitutional content, see, e.g., Montoy v. State, 278 Kan. 769, 120 P.3d 306, 309 (2005), I believe this would read more into the Clause than the framers intended.

Another analytical difficulty involves the assumption that educational outcomes reflect the Assembly’s efforts in providing for a thorough and efficient system. A range of student scores will inevitably be reflected on standardized tests, and overall achievement levels will inevitably vary by district. Sound reasoning dictates that student performance is determined, at least in part, by intangible factors such as parental support, a school environment conducive to learning, teacher quality, peer pressure, and effective administration. See City of Pawtucket v. Sundlun, 662 A.2d 40, 59 (R.I. 1995) (“Recent studies have indicated that educational achievement by students is most clearly a function of parental involvement, not necessarily. increased spending.” (footnote omitted)); cf. Rodri guez, 411 U.S. at 42-43, 93 S.Ct. at 1302 (remarking on the controversy surrounding the correlation between spending and educational quality). Although additional funding may help, within this context it seems possible for the Legislature to fulfill its duty to “provide for” the maintenance and support of a thorough and efficient system and still be left with a .system that underperforms due to intractable social factors rather than constitutionally inadequate funding. Thus, to measure constitutional compliance (aside from mandating uniform per-pupil spending), Pennsylvania courts would have to account for these types of influences and determine whether identified performance shortfalls are due tó inadequate funding or other factors beyond legislative control — a task it is ill-suited to perform.

To the extent accommodations in the standards are needed for districts with acute socioeconomic problems, the courts would need to engage in the legislative and administrative task of selecting acceptable threshold scores for each tested subject area as well as minimum district-wide proficiency rates based on a comprehensive picture of such conditions as they exist in each school district. Courts would also need to entertain debates concerning what is necessary, or merely optional, for an education to be considered adequate. See generally Thompson v. Engelking, 96 Idaho 793, 537 P.2d 635, 656 (1975) (Shepard, J., concurring) (“Arguments erupt at the drop of a hat as to what is or is not necessary in an educational system, what is or is not a- frill ... [; w]hat some denominate frills are asserted by others as necessary to the fullrounded education- experience and enrichment of the future life of our children”) The judicial branch lacks the wherewithal to resolve these kinds of disputes. See Michael Heise, The Courts, Educational Policy, & Unintended Consequences, 11 Cornell J.L. & Pub. Pol’y 633, 664 (2002) (hereinafter Unintended Consequences) (“Courts are structurally ill-equipped to make the sometimes delicate policy tradeoffs incident to the school ffl nance enterprise.”); Comm. for Educ. Rights v. Edgar, 174 Ill.2d 1, 220 Ill.Dec. 166, 672 N.E.2d 1178, 1193 (1996) (“[T]he question of whether the educational institutions and servicés in Illinois are ‘high quality’-is outside the sphere of the judicial function”). Additionally, and as the highest court of one of our' sister states has expressed,

there are a multitude of policy decisions that go into state funding decisions, including consideration of federal mandates, the school district’s'local efforts and ability to süpport its schools, and the State’s ability to provide funding. In brief, it is beyond our ken to determine what is -adequate funding for public schools.

Heineman, 731 N.W.2d at 181.

To the degree the costing-out study is claimed to have already taken into account the pertinent social, administrative, and other components and resolved these types of issues — thereby relieving the. judiciary of .any responsibility save directing the government to fund school districts at the levels reflected in the study — the Petition alleges that the study demonstrates the per-pupil cost of an education permitting students to meet the established performance standards. See Petition ¶¶3, 6, 12, 120, 121, 124, 126. As explained, however, those performance objectives cannot simply be equated with constitutional norms in relation to thoroughness and efficiency.

Plaintiffs’ suggested approach has-practical drawbacks as well. It would give rise to a situation in which a finding of unconstitutionality could be remedied by a lowering of the achievement parameters without altering the educational program being delivered. Relatedly, it could incentivize the political branches to set targeted proficiency levels artificially low, or dispense with them entirely, as a means of narrowing their legal exposure and avoiding judicial intervention. See' Unintended Consequences, 11 Cornell J.L. & Pub. Pol’y at 657-58 (referring to this phenomenon as “policymaking chill” and positing that “[rjational assessments of otherwise desirable [education] policies could plausibly change if the effective cost of such a policy reaches the levels suggested by recent [judicial] finance decisions” in other states where the court used present educational standards as a baseline for determining constitutionally-required funding levels). In this regard, and as noted, nothing in the text or history of. the Education Clause commands that the General Assembly enact statewide .academic achievement standards or require school districts to administer standardized tests provided by the state. The approach suggested by Plaintiffs might thus do little to enforce Education Clause compliance and could ultimately prove counterproductive.

Finally, it should not be overlooked that any declaration that the Legislature is in violation of the Education Clause would have little practical effect absent judicial monitoring to ensure compliance with judicial directives. This circumstance is reflected in Plaintiffs’ prayer for relief, in which they ask that the Commonwealth Court “[r]etain continuing jurisdiction over this- matter until such time as [it] has determined that [Defendants] have, in fact, fully and properly fulfilled its orders.” Petition ¶322, The judicial branch would then become entangled in ongoing school-funding litigation, réquiring continuing oversight of a co-equal branch of government, see, e.g., Claremont Sch. Dist. v. Governor, 147 N.H. 499, 794 A.2d 744, 760 (2002) (noting that the parties had availed themselves of the court’s continuing jurisdiction, resulting in eight subsequent .state supreme court opinions in - nine years), which, in turn, would be in tension with the separation-of-powers doctrine. See Okla. Educ. Ass’n v. State, 158 P.3d 1058, 1066 (Okla. 2007) (expressing that the plaintiffs’ request to -have the court monitor and oversee the legislative body would cause the court to invade that body’s power to determine policy); Ex Parte James, 836 So.2d 813, 819 (Ala. 2002) (per curiam) (“[A]ny specific remedy that the judiciary could impose would,- in order to be effective, necessarily involve a usurpation of that power entrusted exclusively to the Legislature.”).

Upon review of similar disputes leading to protracted judicial oversight and litigation in other jurisdictions, I find resonance in the Nebraska Supreme Court’s description that “[t]he landscape is littered with courts that have been bogged down in the legal quicksand of continuous litigation and challenges to their states’ school funding systems.” Heineman, 731 N.W.2d at 183; see also id. at 182-83 (discussing the difficulties encountered by courts in Arkansas, Kansas, Texas, Alabama, and New Jersey); Sundlun, 662 A.2d at 63 (expressing that the New Jersey Supreme Court’s attempt to define what constitutes a “thorough and efficient” education has plunged that tribunal into a “morass,” and concluding that the “volume of litigation [in New Jersey] and the extent of judicial oversight provide a chilling example of the thickets that can entrap a court that takes on the duties of a Legislature”).

Accordingly, I believe we should continue to view the concept of an adequate education attainable via a thorough and efficient system as being a function of educational policy choices made by the Legislature and involving public policy concerns which are properly the domain of legislative discretion. Accord Edgar, 220 Ill.Dec. 166, 672 N.E.2d at 1191. Consistent with our precedent, therefore, I would hold that such matters are “exclusively within the purview of the General Assembly’s powers, and they are not subject to intervention by the judicial branch of our government.” Marrero II, 559 Pa. at 20, 739 A.2d at 114 (internal quotation marks and citation omitted).

B. The reasonable-relation standard

As outlined above, the parties differ over whether the present education-funding legislation bears a “reasonable relation” to the provision of a thorough and efficient system of education. A review of the reasonable-relation standard as it developed for Education Clause purposes reveals that its purpose has become distorted. In its phrasing it is similar to the “rational basis” standard applied in the equal protection and due process contexts — which pertains to whether a legislative classification is rationally related to the advancement of a legitimate state interest. The Court has indicated, however, that the reasonable-relation standard is even more deferential as it is only concerned with whether the legislation “relates to the purpose of’ the Education Clause “without regard to the way the legislature has chosen to fulfill” that purpose. Reichley, 533 Pa. at 527, 626 A.2d at 128 (emphasis added).

Thus, beginning in Danson and continuing through Marrero II, the Court has employed the reasonable-relation litmus as a minimal test of legislative purpose — that is, to assess whether a. conceptual or logical-connection exists between the legislative scheme and the implementation of a statewide system of education. See, e.g., Danson, 484 Pa. at 427, 399 A.2d at 367. Further, the Court has never invalidated an education-funding scheme on the grounds that it failed the reasonable-relation test. Marrero II, for example, held that the Legislature had satisfied the standard by enacting a number of laws directly relating to the operation and funding of the state’s public school system. It did not undertake any analysis of whether the particular funding scheme was likely to make the system “thorough and efficient,” as it considered that question to be political in nature and unsuitable to judicial determination. See Marrero II, 559 Pa. at 17-20, 739 A.2d at 112-14. Applied in this way, the reasonable-relation standard amounts to virtually no standard at all because any legislative scheme purportedly enacted to discharge the General Assembly’s obligations under the Education Clause — including the School Code, see Burger v. Bd. of Sch. Dirs. of McGuffey Sch. Dist., 576 Pa. 574, 584, 839 A.2d 1055, 1061 (2003)—will pass scrutiny regardless of whether a thorough and efficient system exists in reality or in name only.

This state of affairs raises doubts about whether the reasonable-relation standard was intended to be used in such a fashion. It is thus helpful to inquire how the standard originated in the Education Clause context and ascertain whether its later use comports with its initial purpose.

As discussed, Teachers’ Tenure Act — the seminal case in this regard — involved a challenge to the Tenure Act based on a contention that the enactment impaired contractual obligations. See Teachers’ Tenure Act, 329 Pa. at 223 & n.8, 197 A. at 352 & n.8 (quoting PA. CONST, art. I, § 17 (“No ... law impairing the obligation of contracts ... shall be passed.”)). The Court discussed the “power” conferred upon the Legislature by the Education Clause and determined that the Tenure Act was valid because it bore a “reasonable relation” to the purpose for which that power was given. Id. at 223-25, 197 A. at 352-53. Teachers’ Tenure Act, in other words, used the reasonable-relation standard to assess whether the challenged legislation fell within the scope of legislative authority, not whether it fulfilled legislative obligations.

The same dynamic was at work in Reichley. In that matter, the trial court found that labor strikes tend to disrupt public education. As a consequence, the trial court invalidated a portion of the Public Employee Relations Act permitting such strikes. Relying on the reasonable-relation standard, this Court reversed. The Court concluded that, because the legislation was aimed at resolving injurious labor disputes, it bore a reasonable relation to legislative authority as granted under the Education Clause.'

This type of evaluation is not limited to the education arena. It has also been undertaken to evaluate whether a state statute constitutes an appropriate exercise of the state’s police powers. To be a valid exercise, the act must bear a “rational relation to public safety, health, morals or general welfare[.]” Appeal of Rolling Green Golf Club, 374 Pa. 450, 454, 97 A.2d 523, 525 (1953) (internal quotation marks and citation omitted); see also Price v. Smith, 416 Pa. 560, 562-63, 207 A.2d 887, 888 (1965) (same as to local ordinances).

The federal cases are similar. In National Railroad Passenger Corp. v. Boston & Maine Corp., 503 U.S. 407, 112 S.Ct. 1394, 118 L.Ed.2d 52 (1992), a taking accomplished pursuant to a federal statute was permissible so long as it was “rationally related” to a public use as required under the Fifth Amendment. Id. at 422, 112 S.Ct. at 1404 (quoting Hawaii Hous. Auth. v. Midkiff, 467 U.S. 229, 240-41, 104 S.Ct. 2321, 2329-30, 81 L.Ed.2d 186 (1984)). More recently, the Supreme Court noted that, “in determining whether the Necessary and Proper Clause grants Congress the legislative authority to enact a particular federal statute, we look to see whether the statute constitutes a means that is rationally related to the implementation of a constitutionally enumerated power.” United States v. Comstock, 560 U.S. 126, 134, 130 S.Ct. 1949, 1956, 176 L.Ed.2d 878 (2010); see also id. at 134-35, 130 S.Ct. at 1956-57 (citing Cases). See generally Kennedy v. Mendoza-Martinez, 372 U.S. 144, 211, 83 S.Ct. 554, 589, 9 L.Ed.2d 644 (1963) (Stewart, J., dissenting) (“As with any other exercise of congressional power, a law which imposes deprivation of citizenship, to be constitutionally valid, must bear a rational relationship to an affirmative power possessed by Congress under the. Constitution.”). ⅛

In summary, then, the reasonable-relation test was not designed to evaluate whether a branch of state-government has fulfilled its constitutional obligations. It was wrongly applied in this way in Danson and Marrero II, and the experience of those cases teaches that the standard has little efficacy as means of enforcing legislative obligations in any event, instead, the litmus, when applied properly, is utilized to ascertain whether the government has the authority to legislate, or otherwise act, in the manner subject to challenge, as reflected in Teachers’ Tenure Act, Reichley, and federal cases such as those discussed above.

In the present controversy, the substance of Plaintiffs’ allegations is that the political branches have not acted sufficiently to fulfill their duties, not that they have acted beyond the authority assigned to them by the state charter. The parties’ opposing arguments concerning whether the reasonable-relation standard is currently satisfied are therefore misplaced. I would thus conclude that any present reference to the reasonable-relation standard cannot provide an independent basis for relief.

III. The Equal Protection Clause Claim

Plaintiffs also contend that the Commonwealth Court erred in holding that their equal protection claim was barred under the political question doctrine. They note that, although Danson denied relief on -such a. claim, its analysis reflects a merits disposition based on the challengers’ failure to assert gross disparities in funding, among school districts. Plaintiffs argue they, by contrast, allege that these types of disparities exist because poorer school districts have a pronounced disadvantage in raising local revenue as compared to wealthier ones notwithstanding that the former often have higher tax rates. They note that their ability to boost local taxes is impeded further by a dearth of high-value properties combined with ■limitations on yearly property tax increases imposed pursuant to the Taxpayer Relief Act. See Brief for Appellants at 21,

More generally, Plaintiffs offer that education-related equal protection challenges are ordinarily justiciable because courts are able to discern from the established method of raising and distributing funds whether less-affluent school districts are subject to inferior treatment as compared to wealthier ones. They continue that this may be accomplished without delving into questions of funding “adequacy” or otherwise implicating the Baker factors. As an example, Plaintiffs suggest a hypothetical example in which the state arbitrarily allocates a higher sum to wealthy districts than to poor ones. See Brief for Appellants at 23. Therefore, Plaintiffs contend that Marrero ITs focus on determining what constitutes an adequate education and appropriate funding for such an education is immaterial to the present issue. They add that, in any event, the political question doctrine is disfavored where a claim involves an alleged infringement of individual rights — -here, the right to receive an education. See id. at 23-24, 43-44; ‘ Reply Brief for Appellants at 8 n.5, 20 (quoting Sch. Dist. of Wilkinsburg v. Wilkinsburg Educ. Ass’n, 542 Pa. 335, 343, 667 A.2d 5, 9 (1995) (stating that, under the Education Clause, public education is a “fundamental right” in Pennsylvania)). Finally, Plaintiffs reference decisions from other states in which an education-funding equal protection challenge was sustained on its merits. See Brief for Appellants at 25.

The Executive Defendants respond that Plaintiffs’ Equal Protection Clause claim is intertwined with their Education Clause claim. They assert, as well, that the Petition’s allegations do not support Plaintiffs’ contention that determining what constitutes an adequate education is unnecessary within the equal protection context; they state that such allegations are, instead, framed in terms of an equal opportunity to obtain an “adequate” education. More generally, the Executive Defendants maintain that the framers considered the potential for inequalities between school districts, but they specifically rejected uniform funding in favor of local control. Thus, the Executive Defendants reason that it would be illogical to hold that the Equal Protection Clause “forbids what the Education Clause was specifically designed to per-mití.]” Brief for Executive Appellees at 32.

They also contend that Plaintiffs misconstrue Drnson, which held that the appellants failed to state a justiciable cause of action without distinguishing between the Equal Protection and Education Clause claims raised. They remark, moreover, that no authority exists.for Plaintiffs’ position that the political question doctrine does not apply to equal protection claims, noting that Baker itself involved an equal protection challenge. Lastly, as to whether education is a fundamental right, the Executive Defendants argue that the statement to this effect in Wilkinsburg is mere dicta. They observe that the Wilkinsburg Court did not reach the merits of the issue raised in that dispute, which involved a challenge to a school board’s authority to enter into a contract with ■ a private company; the Court instead simply held that the trial court had erred by issuing a preliminary injunction without first holding an eviden-tiary hearing.

The Legislative Defendants also disagree with Plaintiffs as regards the Dan-son decision, suggesting that its holding— that the judiciary may not intrude upon an education funding scheme that bears a reasonable relation to complying with the Education Clause — applies to Plaintiffs’ equal protection claim. As well, they disagree that Damon reached the merits of the question raised, observing that Danson, like the Commonwealth Court in the present matter, dismissed the case on preliminary objections. They also raise several alternative arguments; asserting, for example, that , the equal-protection claim is conceptually deficient because it fails to identify a. statutory classification. See Brief for Legislative Appellees at 44-52.

Plaintiffs’ argument is not based on the Fourteenth Amendment’s Equal Protection Clause, but on Article III, Section 32 of the state charter. That section prohibits special laws regulating the affairs of school districts. See PA. Const, art. Ill, § 32(1); see also supra note 4.

Pennsylvania courts do not, as a rule, decline to reach the merits of Section 32-based challenges to laws regulating education. See, e.g., W. Mifflin Area Sch. Dist. v. Zahorchak, 607 Pa. 153, 164-65, 4 A.3d 1042, 1049 (2010) (sustaining an Article III, Section 32 challenge to a state law enacted to aid a single school district); Harrisburg Sch. Dist. v. Zogby, 574 Pa. 121, 141, 828 A.2d 1079, 1091 (2003) (rejecting, on its merits, an Article III, Section 32 challenge to an act designed to aid a small, but open, class of school districts). Here, Plaintiffs’ contention does not rest on Section 32’s preclusion of special laws as such. Instead, it is based on the provision’s more general guarantee, as developed through judicial interpretation, that the citizens of .this state enjoy equal protection under the law. See Pa. Tpk. Comm’n v. Commonwealth, 587 Pa. 347, 363, 899 A.2d 1085, 1094 (2006). In this sense, although Plaintiffs’ position is not expressly based on federal equal protection guarantees, it is similar to an equal-protection .claim brought under the Fourteenth Amendment. See supra note 4.

In reference to such claims, where the challenged governmental action does not restrict “fundamental” or “important” rights and does not burden a suspect or a quasi-suspect classification, it does not violate the Equal Protection Clause as long as it is rationally related to a legitimate governmental interest. See Small, 554 Pa. at 615, 722 A.2d at 672. However, if a statutory classification disadvantages a suspect class or burdens a fundamental right, it will only be sustained if it survives strict scrutiny. See Smith v. Coyne, 555 Pa. 21, 29, 722 A.2d 1022, 1025 (1999).

A. The fundamental-right/strict-scrutiny argument

Plaintiffs’ argument implicates two conceptual bases for equal protection scrutiny. The first rests on the premise that education is a fundamental constitutional right which has been unduly burdened by insufficient funding; thus, any statutory classification must be subjected to strict scrutiny. Regardless of whether Plaintiffs’ description of education as a “fundamental” right is valid in a general or colloquial sense, from a legal perspective — that is, in terms of the applicable level of judicial scrutiny — it cannot be supported. As this Court observed in Danson, the Rodriguez Court specified that

the key to discovering whether education is ‘fundamental’ is not to be found in comparisons of the relative societal significance of education as opposed to ■subsistence or housing. Nor is it to be found by weighing whether education is as important as the right to travel. Rather, the answer lies in assessing, 'whether there is a right to education explicitly or implicitly guaranteed by the Constitution.

Rodriguez, 411 U.S. at 33, 93 S.Ct. at 1297. Rodriguez continued that education is not among the rights expressly protected by the United States Constitution, and that its “undisputed importance” cannot alone supply a “basis for saying it is implicitly so protected.” Rodriguez, 411 U.S. at 35, 93 S.Ct. at 1297; see also Plyler v. Doe, 457 U.S. 202, 223, 102 S.Ct. 2382, 2398, 72 L.Ed.2d 786 (1982) (acknowledging that education is not a fundamental right under the federal Constitution).

Similarly, Article I of the Pennsylvania Constitution, known as the Declaration of Rights, enumerates various rights and freedoms as being inherent to mankind, including life, liberty, property, and reputation. See PA. Const, art. I, § 1; see also id. §§ 3-10 (listing other rights such as religious freedom, the right to vote, trial by jury, freedom of expression, freedom from unreasonable searches and seizures, and rights associated with criminal defendants). Article I rights are carved out of the government’s general powers, see id. § 25, and, being inherent, they are secured rather than bestowed by the Constitution. See Driscoll v. Corbett, 620 Pa. 494, 511, 69 A.3d 197, 208 (2013).

Although there cannot be any doubt that education is of vital social importance to the Commonwealth of Pennsylvania, from a constitutional standpoint the Education Clause stands on a different footing in terms of individual rights. The text of that clause lacks any language indicating that a right to education is either granted to the people or inherent to mankind. Cf. Robinson Twp., 623 Pa. at 607, 83 A.3d at 927 (noting that the Legislature’s Article III duties are “limited fundamentally’ by the rights “reserved to the people” in Article I). Also, Article I does not itself mention education, nor does any other aspect of the state charter suggest that a free public education was intended by the framers to be a fundamental right. It is not within this Court’s purview to declare it so based on our own estimation of its critical social importance. See generally Rodriguez, 411 U.S. at 33, 93 S.Ct. at 1297 (“It is not the province of this Court to create substantive constitutional rights in the name of guaranteeing equal protection!)]”).

Moreover, Marrero II stated expressly that the Education Clause does not confer individual rights upon students, but rather, imposes a duty on the Legislature. See Marrero II, 559 Pa. at 17, 739 A.2d at 112. Thus, to the extent an individual right to public education exists in Pennsylvania, it is statutorily conferred and, as such, “it is limited by statutory provisions.” Lisa H. v. State Bd. of Educ., 67 Pa.Cmwlth. 350, 356, 447 A.2d 669, 673 (1982), aff'd per curiam, 502 Pa. 613, 467 A.2d 1127 (1983); accord 24 P.S. § 13-1301. Notably, there is no present claim before this Court that a statutory violation has occurred.

As for the tension between Marrero II and Wilkinsburg, the former rejected an explicit request for a declaratory judgment stating that the Education Clause confers an individual right tó a thorough and efficient system of education. See Marrero I, 709 A.2d at 958. Thus, in Marrero II the constitutional igsue was joined and a holding was reached. By contrast, Wilkins-burg’s indication that education constitutes a fundamental right comprised dicta unsupported by authority.1 would now disapprove that statement and hold, consistent with Marrero II, that the Education Clause imposes an obligation on the Legislature, but it does not confer a fundamental constitutional right upon individuals capable of triggering strict scrutiny within an equal protection context.

Moreover, Plaintiffs do not assert that the' government has burdened a suspect class. See D.P., 636 Pa. at 586 n.8, 146 A.3d at 210 n.8 (“Strict scrutiny is separately triggered under the Equal Protection Clause if-the legislation employs a suspect classification.”). The Petition’s averments suggest that, to the extent a class exists, it is comprised of a number of low-wealth school districts which are unable to raise as .much money through taxation as other school districts. See, e.g.,- Petition ¶287 (alleging that the 2011 funding cuts and dependence on local taxes have disproportionately impacted the state’s 50 poorest districts). Thus, the purported, class is based on wealth and geography. See id. ¶8 (alleging that the funding system violates equal protection “because it turns the caliber of public education into an accident of geography”).

These types of identifying characteristics do not give rise to a suspect or quasi-suspect classification. See Small, 554 Pa. at 615 nn.14-15, 722 A.2d at 672 nn.14-15 (observing that suspect classes are race, national origin, and,, for state-law purposes, alienage, and that quasi-suspect classes are gender and legitimacy). Because no fundamental right or suspect class is .involved, I would conclude that Plaintiffs cannot prevail on' their contention that, to be valid, the purported classification must survive strict scrutiny, i.e., be justified by a compelling government interest and be narrowly tailored to serve that-interest.

B. The no-rational-basis argument

In the alternative, Plaintiffs maintain that, even if strict scrutiny does not apply, the manner in which the Legislature funds public eduóation fails the more deferential rational basis test because it is arbitrary and irrational. See Petition ¶305' (describing the “levels and allocation” of state public-school funding as “irrational, arbitrary,- and not reasonably calculated to ensure that all Pennsylvania school children have access - to an adequate education”). Under the rational-basis framework, the question is whether the legislative classification is rationally related to the promotion of a legitimate state interest. See Kramer v. WCAB (Rite Aid), 584 Pa. 309, 335, 883 A.2d 518, 534 (2005). See generally Brief for Appellants at 26 (implying that the school funding scheme does not “serve[] a legitimate government interest”).

Athough, as noted, there is no per se rule against reaching the merits of an Article III, Section 32 challenge to state laws regulating education, I agree with Defendants’ suggestion that, here, the claim is intertwined, or “enmeshed,” with the Education Clause claim. Brief for Legislative Appellees at 24 n.9; see also Brief for Executive Appellees, at 31 (asserting that the two claims cannot be “disentangled”). The Supreme Court has recognized that an equal protection claim is not justiciable if, in substance, it is enmeshed with “political question elements” which cause claims under a separate constitutional provision- to implicate the political question doctrine. Baker, 369 U.S. at 227, 82 S.Ct. at 715. For its part, Baker held that the one-man-one-vote equal-protection claim raised in that matter was not enmeshed with the political question elements involved in a cause of action brought under the Article IV, Section 4, known as the Guaranty Clause. See U.S. Const, art. IV, § 4 (guaranteeing to each state a republican form of government); Baker, 369 U.S. at 232, 82 S.Ct. at 718. Baker noted, however, that 60 years earlier the Court did recognize such an entanglement in Pacific States Telephone & Telegraph Co. v. Oregon, 223 U.S. 118, 32 S.Ct. 224, 56 L.Ed. 377 (1912).

‘ In Pacific States, a corporation challenged' a tax levied by popular initiative, a process that had been included in the Oregon charter via constitutional amendment several years earlier. The company claimed that the initiative process itself was contrary to the Guaranty Clause, and that as such, the tax violated several other constitutional rights, including the right to equal protection. The Supreme Court denied relief. It expressed that the latter contention rested on a preliminary finding that the initiative procedure violated the Guaranty Clause, which in turn implicated a non-justiciable claim. As a consequence, the equal protection cause of action was deemed non-justiciable. See id. at 150-51, 32 S.Ct. at 231. See generally Cantor v. Supreme Court of Pa., 353 F.Supp. 1307, 1316-17 (E.D. Pa. 1973) (comparing the analyses in Baker and Pacific States).

A review of the Petition' here indicates that the averments relating to equal protection'are framed in-terms of whether the students in poorer school districts have been denied an equal opportunity to obtain an “adequate” education. See Petition ¶¶8, 13, 94, 262, 290-92, 308-10, 313-14, 317, 320-21. Addressing that question requires a prior agreement that the premise — that the lower total expenditures per student in the poorer districts were depriving the students in those districts- of an adequate education — is susceptible of judicial determination. Given my earlier conclusion that the -ascertainment of what constitutes a constitutionally adequate education is a matter of public policy left to the political branches and lies outside the realm of the judiciary, I would find that, as in Pacific States, the equal-protection claim as stated here is enmeshed with the initial, non-justiciable, claim.

Still, Plaintiffs argue that, regardless of the wording in the Petition, their equal protection argument, in fact, rests solely on disparities in funding as between poorer and wealthier 'districts, and not on the premise that students in poorer districts are failing.to receive an “adequate” education. They suggest the alleged equal protection violation arises solely from the fact that poorer school districts have less total education funding,’ meaning students in those districts are receiving an inferior education. See Brief for Appellants at 22. Also, according to Plaintiffs, the complained-of funding discrepancies are due to legislative choices because, under state law, the overall funding arrangement relies heavily on local taxes. For the sake of decision, I would afford Plaintiffs the benefit of any doubt on this question and consider their equal protection claim on the terms they now advance. Stated thus, the question is justiciable and its substance can be analyzed without reference to the concept of educational adequacy.

Legislation duly enacted by the General Assembly enjoys a strong presumption of validity. It will only be declared void if it clearly, palpably, and plainly violates the Constitution. Any doubts about its validity are resolved in favor of a finding of constitutionality. See Commonwealth v. Bullock, 590 Pa. 480, 487, 913 A.2d 207, 211-12 (2006). The overall question for purposes of a Defendants’ demurrer is whether the Petition’s averments are legally sufficient to state a claim for relief. See Pa.R.C.P. No. 1028(a)(4); Mazur v. Trinity Area Sch. Dist., 599 Pa. 232, 240, 961 A.2d 96, 101 (2008). As applied here, the issue is whether such averments identify a statutory classification which bears no rational relationship to a legitimate state interest.

As discussed, the classification identified in the Petition involves geography and wealth. It consists of a group of school districts which have a diminished ability to raise local revenues as compared to wealthier districts. If the school financing arrangement were to discriminate against these districts, for example, by allocating less state money to them due to their lower wealth (as in the hypothetical example Plaintiffs propose), such discrimination would clearly be unrelated to a legitimate government interest.

According to the Petition, however, the state uses a formula which provides more aid to poorer districts than to wealthier ones. See Petition ¶¶262-67. This is entirely rational: such districts need more aid than wealthier ones, and the provision of more money rationally relates to the legitimate governmental interest in lessening the funding disparity between the two groups of school districts and helping poorer districts with costs associated with disadvantaged students. While the Petition alleges that the state should provide even more aid than it currently does, see Petition ¶11 (“Although the state has made some effort to close that gap, contributing twice as much per student to Panther Valley as it did to Lower Merion, that still left Panther Valley with less than half the combined state and local funding of Lower Merionf]”), the government’s failure to do so does not suggest it is treating poorer districts in an inferior manner to wealthier ones or that its funding formula is not rationally to a legitimate state interest.

Insofar as the claim is based on the predicate that the statutory scheme depends too heavily on local tax revenue, our precedent and that of the United States Supreme Court establish that the government has a rational basis for relying to a large degree on such revenue as a means of conforming with the framers’ intent to maintain local decisional authority over the affairs of school districts. The Petition discounts such local authority as “illusory” under the current arrangement because poorer school districts do not control the standards to which their students are held or the amount of money at their disposal. Petition ¶¶9, 294. Such a contention, even if accepted as true, speaks to a circumstance — possibly a temporary one in light of recent legislation such as Act 35 — which does not undermine the validity of the state’s overall interest in preserving such oversight at the local level. I do not disallow that some school districts, especially poorer ones, may be willing to sacrifice local control for more state funding. Again, however, such a circumstance, even if proved, would not speak to the legitimacy of the government’s overall interest as it pertains to school districts generally.

I would conclude, then, that the aver-ments in the Petition are legally insufficient to make out a viable cause of action under the Equal Protection Clause — and, consequently, that the Commonwealth Court acted properly in sustaining Defendants’ demurrer to that count of the Petition.

IV. Conclusion

For the foregoing reasons, I would affirm the order of the Commonwealth Court. Accordingly, I respectfully dissent.

DISSENTING OPINION

JUSTICE BAER

I join Chief Justice Saylor’s well-reasoned Dissenting Opinion. I write separately to note that, in my view, the Majority unwisely discards this Court’s precedent which holds that inquiry into whether the General Assembly is satisfactorily providing “for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth” presents a non-justiciable political question. E.g., Marrero ex rel. Tabalas v. Com., 559 Pa. 14, 739 A.2d 110 (1999). I emphasize that, ultimately, the Majority’s decision only allows Appellants’ constitutional claims to survive preliminary objections, and Appellants undeniably have to overcome a considerable burden to prove that the educational scheme adopted by the General Assembly fails to pass constitutional muster. See Bilbar Const. Co. v. Bd. of Adjustment of Easttown Twp., 393 Pa. 62, 141 A.2d 851, 855 (1958) (“The rule is well established that the burden of proving clearly and unmistakably the unconstitutionality of a legislative enactment is upon the person so asserting.”). Yet, by holding as it does, the Majority has placed the judiciary in the untenable role of second-guessing the General Assembly’s educational policy decisions.

To be clear, I am empathetic to Appellants’ cause, as a quality public education system is vital. However, the phrase “thorough and efficient,” as it is used in the Education Clause, does not lend itself to a readily definable legal concept. Further, and perhaps more importantly, the judicial branch is ill-equipped to determine whether a particular educational scheme meets the disparate needs of the approximately 500 school districts in this Commonwealth. Indeed, I believe that the judiciary encroaches on the General Assembly’s policy and legislative roles by engaging in such determinations. Thus, to avoid intrusion on the separation of powers, these questions should be left exclusively to the General Assembly to consider.

Finally, I find that the Majority’s decision has opened the door to the possibility of the judiciary being entangled in decades of protracted litigation over legislative policy decisions /regarding the Commonwealth’s educational system. Like the Chief Justice, I heed the warning of the Supreme Court of Nebraska: “The landscape is littered with courts that have, been bogged down in the. legal quicksand of continuous litigation and challenges to their states’ school funding systems.” Nebraska Coal. for Educ. Equity & Adequacy (Coal.) v. Heineman, 273 Neb. 531, 731 N.W.2d 164, 183 (2007). Rather than miring our courts in such quicksand, I would determine that we should abstain from addressing the political question as to whether the General Assembly is properly providing “for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth! J’ 
      
      . This 'case was reassigned to this author.
     
      
      . See PA. Const, art. Ill, § 14 ("The General Assembly shall provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.”). While the constitutional mandate is directed solely to the General Assembly, the remaining Commonwealth Respondents, who raise no specific challenge to their inclusion as parties, are named because Petitioners seek declaratory and injunctive relief that would constrain the executive branch’s administration and enforcement of the challenged school financing scheme.
     
      
      . Petitioners state their equal protection claim solely in terms of Article III, Section 32 of our Constitution, which by its terms proscribes the enactment of "local or special laws” when the circumstance "can be provided for by general law.” Unlike the Fourteenth Amendment to the United States Constitution, Section 32 does not speak expressly in terms of equal protection. Nonetheless, we long have gleaned equal protection principles from Section 32, which we have held is substantially coterminous with the federal Equal Protection Clause. See Balt. & Ohio R. Co. v. Dep’t of Labor & Indus., 461 Pa. 68, 334 A.2d 636, 643 (1975) ("[T]he content of the two provisions is not significantly different.”).
     
      
      
        . See Malone v. Hayden, 329 Pa. 213, 197 A. 344, 352 (1938) (hereinafter "the Teachers’ Tenure Act Case”); Danson v. Casey, 484 Pa. 415, 399 A.2d 360 (1979); Marrero v. Commonwealth, 559 Pa. 14, 739 A.2d 110 (1999) (hereinafter "Marrero II").
      
     
      
      . Overruled on other grounds by Fed. Power Comm'n v. Natural Gas Pipeline Co. of Am., 315 U.S. 575, 62 S.Ct. 736, 86 L.Ed. 1037 (1942).
     
      
      . The following account draws principally upon John L. Gedid, History of the Pennsylvania Constitution, in The Pennsylvania Constitution: A Treatise on Rights and Liberties 31-72 (Ken Gormley et at, eds. 2004), and upon the exemplary, unpublished single-judge Commonwealth Court opinion written by the Honorable Dan Pellegrini in Pennsylvania Association of Rural & Small Schools v. Ridge, 11 M.D. 1991, slip op. at 86-105 (Cmwlth. Ct. July 9, 1998) (hereinafter “PARSS"), affirmed by PARSS v. Ridge, 558 Pa. 374, 737 A.2d 246 (1999) (per curiam). A copy of Judge Pellegri-ni’s opinion in PARSS is appended to Petitioners’ brief in. the instant appeal. We provide direct citations to these sources only where quotations are drawn from them. Additional intertextual citations refer to sources with ■ which we supplement the above authors’ accounts.
     
      
      . The method of selecting judges in Pennsylvania repeatedly has changed over the years. Presently, the selection of judges by partisan elections, subject to decennial retention elections, reflects changes effectuated in the 1968 Constitution. See generally PA. Const, art. V, §§ 12-15.
     
      
      . "The powers not delegated to the United States by the Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.” U.S. Const. amend X,
     
      
      . While, as detailed below, the precise ratio of state funds to local funds comprising the non-federal share of any given school district’s budget will vary from one district to the next, it is worth noting that, overall, the two-to-one ratio of local to state funding approximates the overall ratio in effect nearly two hundred years later. However, as one commentator observes, it was not always so:
      The high[-]water mark for [Pennsylvania] state contributions to public education funding was in 1974-75, when the state reimbursed school districts for 55% of their actual instructional expenses. By 2003-04, that figure had dropped to 34%. The shift was not accidental: in 1983, the state legislature removed language from the School Code which held the state to a goal of paying 50% of statewide district instructional costs.
      Ann L. Martin, Comment, Been There, Done That: What Next? Looking Back & Ahead at Litigation Prospects for School Funding Reform in Pa., 15 Widener L.J. 815, 816 n.6 (2006) (citing The Education and Policy Leadership Center, Pennsylvania Education Finance Primer 7 (Nov. 2005)).
     
      
      . As reflected by the Senate’s passage of a repeal bill in 1835, opposition to the 1834 act was widespread- and fierce, perhaps costing Governor Wolf his job in the 1835 election and leading to the election of repeal-inclined senators and representatives. Thirty-eight of fifty-one counties sent petitions seeking repeal, and at least two more petitioned for modifications. Only eleven counties refrained entirely from seeking changes to the new act. The Famous Speech of Hon. Thaddeus Stevens of Pennsylvania in Opposition,to the Repeal of the Common School Law of 1834, in the House of Representatives of Pennsylvania, April 11, 1835, Introduction, at 3, available at https:// . goo.gl/vZ8GN0 (last reviewed Aug. 28, 2017). Mr, Stevens’ entire speech is worthy of review, but among his observations was that, "[i]f education be of admitted importance to the people under all forms of government, and of unquestioned necessity when they govern themselves, it follows of course that its cultivation and diffusion is a matter of public concern, and a duty which every government owes to its people.” Id. at 4 (emphasis in original).
     
      
      . Interestingly, as a reflection of the Commonwealth’s collective, ongoing commitment to an education that might fairly be called "thorough,” delegates to the 1837 convention defeated an amendment that would have added "common” as a modifier to the Education Clause, In the parlance of that era, such language would have purported to restrict the state’s obligation to the maintenance only of a system of elementary and middle schools, as we define them today. See John Dinan, The Meaning of State Constitutional Education Clauses: Evidence from the Constitutional Convention Debates, 70 Alb. L. Rev. 927, 953 (2007) (quoting 5 Pennsylvania Convention of 1837-1838 290-91).
     
      
      . See Md. Const, art. VIII, § 1; Minn. Const. art. XIII, § 1; N.J. Const, art. VIII, § 4; W.V. Const, art. XII, § 1. In point'of fact, in addition to those states, the same language also appeared in the Constitutions of Illinois and Wyoming. See III. Const, art. X, § 1; Wyo. Const, art. VII, § 1,
     
      
      . This Court previously has observed that the 1874 Constitution "was drafted in an atmosphere of extreme distrust of the legislative body and of fear of the growing power of corporations,” and reflected a "prevailing mood ... of reform.” In re Commonwealth, Dep’t of Transp., 511 Pa. 620, 515 A.2d 899, 901 (1986) (quoting R. Branning, Pennsylvania Constitutional Development 37 (1960)); see Pennsylvanians Against Gambling Expansion Fund, Inc. v. Commonwealth, 583 Pa. 275, 877 A.2d 383, 394 (2005) (agreeing with the above, and noting that the resultant mandates •limiting legislative power "retain their Value even today by placing certain constitutional limitations on the legislative process”).
     
      
      .The transition from a mandate to "establish” a system of education to one requiring "maintenance and support” was described by one delegate to the 1873 convention as a way of recognizing "the existence of that admirable system of public schools which now prevails all over the Commonwealth,” i.e., as a reflection of principle and the status quo, rather than a mandate to effect specific change. Dinan, supra n.11, at 942 (2007) (quoting 2 Pennsylvania Convention of 1872— 73 419-20).
     
      
      . While it may seem strange now, this Court once described this as a "magnificent sum.” Ford v. Sch.-Dist. of Kendall Borough, 121 Pa. 543, 547, 15 A. 812 (Pa. 1888).
     
      
      . Interestingly, according to Petitioners’ allegations as related infra, that concern remains emergent, as low-wealth districts continue to assess taxes upon property in their domains at a much higher rate than those of wealthier districts, while the former still collect significantly less school tax revenue per student than the latter.
     
      
      . Kuren v. Luzerne Cnty., 146 A.3d 715, 718 n.1 (Pa. 2016).
     
      
      . One commentator, addressing the evolution of the “standards-based model” of education, provides a¡ useful shorthand for the components of such an educational paradigm, noting that the model entails "three key components: (1) academic content standards for various subjects identifying what a student should know and be able to do at each grade level; (2) standardized tests designed to gauge student mastery of tírese standards; and (3) a system of accountability for schools, including rewards and consequences based on individual school and district performance.” Jill Am-brose, Note, A Fourth Wave of Education Funding Litigation: How Education Standards & Costing-Out Studies Can Aid Plaintiffs in Pennsylvania & Beyond, 19 B.U, Pub. Int.L.J. 107, 117(2009).
      Executive Respondents reject the thrust of Petitioners’ contention that 1999 marked the initial imposition of academic standards upon school districts. Executive Respondents note that, over fifty years ago, in 1963, in service of the goal of facilitating the "expeditious reorganization” of the Commonwealth’s public school system, 24 Pa.C.S. § 2-290, the General Assembly directed the Department of Education to "develop or cause to be developed an evaluation procedure designed to measure objectively the adequacy and efficiency of the educational programs offered by the public schools” by, e.g., deploying tests to measure "the achievements and performance of -students.” 24 P.S. § 2-290.1; see Brief for Executive Respondents at 23. They note that systematic school and student assessments were administered as early as the 1969-70 school year under the Educational Quality Assurance ("EQA”) program, which was joined, in 1984, by the Testing for Educational Learning and Literacy Skills ("TELLS”), EQA was discontinued in 1988, and, in 1992, TELLS’ was replaced by the first incarnation of the Pennsylvania System of School . Assessment ("PSSA”). This does not strike us as contradictory of Petitioners’ claim that the pervasiveness, rigor, and thoroughness of the tests employed by the Commonwealth in determining the progress of individual students and the success of individual teachers, programs, and schools and their districts increased significantly in 1999, when, by Executive Respondents’ own admission, the PSSA was sub- , stantially overhauled. Id. at 26-27. Passage of the No Child Left Behind Act in 2001 tied federal funding to various federal mandates and standards. See 20 U.S.C. § 6311; Aaron Y. Tang, Broken Systems, Broken Duties:. A New Theory for. School Finance Litigation, 94 Maro. L. Rev. 1195, 1213-14 (2011). In light of the complications associated with this subject, our standard of review prevails and we assume the truth of Petitioners’ averments in this regard. But to the extent that it is material to what follows, we accept as undisputed Executive Respondents’ observation thát standards and measurement have been in play in Pennsylvania public education in one form or another since the 1960s, and that these continue to evolve. That being said, Respondents do not suggest that there is a strong resemblance between the pre-1999 and post-1999 landscape in terms of the frequency, depth, and consequence associated with the exams administered to students who attend Pennsylvania's public schools. Absent that, we are bound to accept the thrust of Petitioners’ assertions .as true to at least that extent.
     
      
      . Act of July 9, 2008, P.L. 846; No. 61, amending Act of Mar. 10, 1949, P.L. 30, No. 14, codified at 24 P.S, §§ 1-101 et seq.
      
     
      
      
        . While we consider this “costing-out” study, infra, to the extent necessary to address the parties’ arguments, it is beyond the scope of this Opinion to delve deeply into the nature of such studies. For a succinct description of the methodologies employed in such studies and how they have been utilized in forming .education policy in other states, as well as a brief description of the specific study conducted at the behest of the Pennsylvania General Assembly, see Ambrose, supra n.18, at 119-22.
     
      
      .Act of Feb. 17, 2009, P.L. 111-5, 123 Stat. 115, codified as amended at 26 U.S.C. §§ 1 et seq.
      
     
      
      
        . Act of June 27, 2006, P.L. 1973, No. 1 (Spec. Sess. No. 1), § 1, codified at 53 P.S. §§ 6926..101, ei seq.
      
     
      
      . Widespread funding shortages and reductions in education expenditures in the wake of 2008's "Great Recession” have been well-documented. See generally Michael A. Rebell, Safeguarding the Right to a Sound Basic Education in Times of Fiscal Constraint, 75 Alb. L. Rev. 1855 (2011).
     
      
      . The considerable time that has passed since Petitioners filed their Petition necessarily renders their allegations dated, in their particulars if not in their overarching propositions. Nonetheless, as a convenience, we utilize the present tense in rendering Petitioners' allegations, with the caveat that certain specific allegations presumably will require updating as this litigation proceeds in the wake of our decision. Notably, while common sense strongly suggests that particular allegations, especially quantifiable averments, will not be accurate at any given moment relative to present circumstances, we nonetheless are bound by this case’s procedural posture to accept Petitioners’ allegations at face value.
     
      
      ,When Petitioners filed their challenge, the state funding formula that applied to the allocation of state funding among school districts was provided by 24 P.S. §§ 25-2502.50 ("Basic education funding for 2010-11 school year”), 25-2502.51 (2011-12 school year), and 25-2502.52 (2012-13 school year). See ■ Act of June 30, 2011, P.L. 112, No. 24, § 26. However, after the Commonwealth Court sustained Respondents’ preliminary objections in this matter, and indeed after briefing was completed before this Court, the General Assembly enacted Act 35, which created a new state funding formula that applied to the 2016-17 school year and applies each year thereafter. See Act of June 1, 2016, P.L. 252, No. 35, § 1, codified at 24 P.S. § 25-2502.53. The effect of this change is addressed infra, at the outset of our discussion of the legal issues presented.
     
      
      . The story is much the same in the Wilkes-Barre Area and Shenandoah Valley School Districts. And since 2011, amicus curiae Philadelphia School District has reduced the number of principals and assistant principals by 40%; teachers by 33%; special education teachers by 22%; career and technical edu-r cation teachers by 37%; and counselors, student advisors, and social service liaisons by 54%. Philadelphia operates 214 schools serving approximately 131,000 students, but employs only sixty-six music teachers and .three full-time-equivalent librarians. The superintendent of the Philadelphia School District, as well as Respondent Department of Education have characterized the state of public education in Philadelphia as "insufficient and unsustainable.” Petition at 82-83 ¶ 200; see id.‘at 83 ¶ 201 (quoting at length a joint filing of ’the Philadelphia School District, the School Reform Commission, and the Department of Education in other litigation describing the "bare-bones” and "unsatisfactory” conditions and "woefully inadequate" staffing levels in the Philadelphia School District).
     
      
      . See generally 22 Pa.Code §§ 4.1 et seq.
      
     
      
      . The Baker Court set forth the following factors to guide the political question analysis:
      Prominent on the surface of any case held to involve a political question is found a textually demonstrable constitutional commitment of the issue to a coordinate political department; or a lack of judicially discoverable and manageable standards for resolving it; or the impossibility of deciding without an initial policy determination of a kind clearly for non[-]judicial discretion; or the impossibility of a court's undertaking independent resolution without expressing lack of the respect due coordinate branches of government; or an unusual need for unquestioning adherence to a political decision already made; or the potentiality of embarrassment from multifarious pronouncements by various departments on one question.
      
        Baker, 369 U.S. at 217, 82 S.Ct. 691; see Robinson Twp. v. Commonwealth, 623 Pa. 564, 83 A.3d 901, 928 (2013); Council 13, AFSCME ex rel. Fillman v. Rendell, 604 Pa. 352, 986 A.2d 63, 75 (2009); Sweeney v. Tucker, 473 Pa. 493, 375 A.2d 698, 706 (1977). The presence of any one Baker factor warrants abstention under the political question doctrine. Baker, 369 U.S. at 217, 82 S.Ct. 691; Blackwell v. City of Phila., 546 Pa. 358, 684 A.2d 1068, 1071 (1996); Zemprelli v. Daniels, 496 Pa. 247, 436 A.2d 1165, 1169 (1981).
     
      
      . The Commonwealth Court did hot rule upon these preliminary objections, which are independent of the justiciability argument upon which the Commonwealth Court relied in sustaining Respondents’ preliminary objections. Accordingly, we do not address them herein. These arguments remain salient upon remand, and our decision is not intended to prejudice Respondents’ right to pursue them further in the court below.
     
      
      . The Commonwealth Court did not treat Petitioners’ Education Clause and equal protection claims discretely, an approach which, as set forth infra, more or less follows from the court's reliance upon Danson and Marrero II.
      
     
      
      . The City of Philadelphia,- as well as several individuals and organizations, have filed ami- ■ cus briefs supporting Petitioners’ position, including the Philadelphia Federation of Teachers, Local 3, of the American Federation of Teachers, together with the American Federation of Teachers Pennsylvania, • AFT; two groups of youth, education, and civil rights advocacy associations led, respectively, by Public Citizens for Children and Youth and the Consortium for Public Education; and a group of individual professors of constitutional law.
     
      
      . We granted Governor Wolf leave to file his ' brief by per curiam Order of September 22, 2016, shortly after we heard oral argument in this matter.
     
      
      . We have described the mootness doctrine as follows:
      [C]ases presenting mootness problems involve litigants who clearly had standing to sue at the outset of the litigation. The problems arise from events occurring after the lawsuit has gotten under way — changes in the facts or in the law — which allegedly deprive the litigant of the necessary stake in the outcome. The mootness doctrine requires that an actual case or controversy must be extant at all stages of review, not merely at thé time the complaint is filed.
      
        Pub. Def.'s Office of Venango Cnty. v. Venango Cnty. Court of Common Pleas, 586 Pa. 317, 893 A.2d 1275, 1279 (2006) (quoting Pap’s A.M. v. City of Erie, 571 Pa. 375, 812 A.2d 591, 599-600 (2002)).
     
      
      . Even if we were to find that the particular claims presented technically were mooted by the passage of Act 35, Petitioners would have a compelling argument for this Court to proceed to decision on the basis that the issues as stated are of importance to the public interest and “capable of repetition yet evading review.” See Commonwealth, Dep’t of Env'l Protection v. Cromwell Twp., Huntingdon Cnty., 613 Pa. 1, 32 A.3d 639, 652 (2011). At the inception of any action such as the one presented — the public importance of which cannot be disputed — there inheres the risk that the General Assembly will move the goalposts by enacting new legislation, a risk that was especially true under the legislation that applied when Petitioners filed their appeal, when the General Assembly had transitioned to ah annual funding process from one applying a formulaic approach indefinitely or over a designated series of years. In any event, this Court is not asked at this juncture to decide the constitutionality of a particular funding formula, but rather whether a claim regarding the constitutionality of any funding formula may be litigated or instead lies entirely outside judicial review.
     
      
      . Scholars have questioned the very existence of a discrete political question doctrine. See Louis Henltin, Is There a “Political Question’’Doctrine?, 85 YALE LJ. 597, 605 (1976) ("[T]he considerations distilled from [earlier cases] by Justice Brennan [in Baker] seem rather to be elements of the ordinary respect which the courts show to the substantive decisions of the political branches.”); id. at 606 ("In such cases ... the court does not refuse judicial review; it exercises it. It is not dismissing an issue as non-justiciable; it adjudicates. It is not refusing to pass upon the power of the political branches; it passes upon it, only to affirm that they had the power which had been challenged and that nothing in the Constitution prohibited the particular exercise of it.”).
     
      
      . Although the lead opinion in Robinson Township did not command a majority of the Court in all particulars, a majority of Justices joined this account of the political question doctrine.
     
      
      . See Herbert Wechsler, Toward Neutral Principles of Constitutional Law, 73 Harv. L. Rev. 1, 7-8 (1959) ("[A]ll the [political question] doctrine can defensibly imply is that the courts are called upon to judge whether the Constitution has committed to another agency of government the autonomous determination of the issue raised, a finding that itself requires an interpretation.”) (emphasis added).
     
      
      . Inasmuch as this responded implicitly to the suggestion that the General Assembly might ever pass a statute concerning education that interfered with its own ability to later repeal or modify that statute, or otherwise change education policy by legislative action, it flirts with incoherence. Unlike the United States Congress, the Pennsylvania General Assembly is not limited to specifically enumerated powers. Rather, it may legislate in any way that is not expressly forbidden by the ■ Pennsylvania or United States Constitution. Compare U.S. Const, art. I, § 8 (enumerating Congressional prerogatives), with Russ v. Commonwealth, 210 Pa. 544, 60 A. 169, 172 (1905) (quoting Norris v. Clymer, 2 Pa. (Barr.) 277, 285 (1845)) ("What the people have not said in the organic law their representatives shall not do, they may do. ... 'The Constitution allows to the Legislature every power which it does not positively prohibit.’ "). Thus, if the question is whether the General Assembly has authority to legislate in the education arena, the answer is "Yes” in virtually every circumstance, provided it stays within constitutional bounds.
     
      
      . See supra n.3. ■
     
      
      . The relationship of school funding and local control is often cited by defenders of hybrid school funding schemes that result in significant district-by-district disparities. Numerous courts and commentators have observed that this relationship is typically con-clusory in its presentation, and disregards the limitations on local prerogatives caused by a paucity of financial resources. The school funding disparities defended by resort to local control in practice disserve that end as to many districts. To cite just one example, the .. Supreme Court of Arkansas has observed as follows:
      Those jurisdictions finding no equal protection violation in a system based on district wealth generally uphold the system of funding by finding a legitimate state purpose in maintaining local control. We find however, two fallacies in this reasoning. First, to alter the state financing system to provide greater equalization among districts does not in any way dictate that local control must be reduced. Second, as pointed out in Serrano v. Priest, [18 Cal.3d 728, 135 Cal.Rptr. 345] 557 P.2d 929, 948 (Cal. 1976), “The notion of local control was a ‘cruel illusion' for the poor districts due to limitations placed upon them by the system itself. ... Far from being necessary to promote local fiscal choice, the present system actually deprives the less wealthy districts of the option.”
      
        Dupree v. Alma, 279 Ark. 340, 651 S.W.2d 90, 93 (1983). Furthermore, recitations of the need for local control cannot relieve the General Assembly of its exclusive obligation under the Education Clause. Regardless of how it balances the minimal education that the Constitution requires to be provided to all students with the limitations inherent in local control and funding (and, again, to suggest that those two are inextricable is tendentious), the General Assembly alone must be held accountable, regardless of whether one perceives the cause of the actionable deficiency to exist at the local or state level. Thus, in Smith v. School District of Upper Darby Township, we held that “[t]he Constitution of 1874 ... directed the Legislature to maintain a 'thorough and efficient system of public schools' .... The school system, or the school districts, then, are but agencies of the state Legislature to administer this constitutional duty.” 388 Pa. 301, 130 A.2d 661, 667 (1957) (quoting Wilson v. Phila. Sch. Dist., 328 Pa. 225, 195 A. 90, 94 (1937)); see Robinson v. Cahill, 62 N.J. 473, 303 A.2d 273, 294 (1973) ("Whether the State acts directly or imposed the role upon local government, the end product must be what the constitution commands. A system of instruction in any district of the State which is not thorough and efficient falls short of the constitutional command. ... [T]he obligation'is the State’s to rectify it.”).
     
      
      . But see Noreen O'Grady, Comment, Toward a Thorough and Efficient Education: Resurrecting the Pennsylvania Education Clause, 67 Temp. L. Rev. 613, 633 (1994) ("[W]hen the Danson [C]ourt characterized these debates as indicating that the framers understood that local communities had the right to -use local tax revenues to expand educational programs subsidized by the Commonwealth, it failed to clarify that those framers also understood that the Commonwealth had a duty to make a ‘good’ or ‘proper’ education available to all children throughout Pennsylvania.”) (footnotes omitted).
     
      
      . See HHAP, 77 A.3d at 599 (reviewing the requirements for standing, including a "real and concrete” controversy, a "substantial, direct, and immediate” interest in the outcome of the litigation, and aggrievement by the complained-of actions or omissions).
     
      
      . Hereinafter, we refer primarily to Marrero I, the Commonwealth Court’s decision that this Court adopted without material supplementation. See Marrero II, 559 Pa. 14, 739 A.2d 110, 114 (1999) ("The foregoing summary of the rationale of the Commonwealth Court discloses no error, but rather a conscientious adherence to precedent which forecloses the relief sought by appellants.”).
     
      
      . Notably, in his Danson dissent, Justice Manderino disputed the majority’s similar characterization of the petitioners' claims in that case, observing that they did not "ask that this Court impose any rigid rules as to how much money each school district must receive.” Danson, 399 A.2d at 369 (Manderi-no, J., dissenting).
     
      
      .There is ample dispute regarding the relationship between the amount of money spent on education and the results of same. For example, in dissent in San Antonio Independent School District v. Rodriguez, 411 U.S. 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973), Justice Marshall observed that ”[i]t is an inescapable fact that if one district has more funds available per pupil than another district, the former will have greater choice in educational planning than will the latter. ... I believe the question of discrimination in educational quality must be deemed to be an objective one that looks to what the State provides its children, not to what the children are able to do with what they receive.” Id. at 83-84, 93 S.Ct. 1278 (Marshall, J., dissenting); see also id. at 83 n.40, 93 S.Ct. 1278 (noting authorities espousing contrary views).
     
      
      . The Nixon Court observed that the "textually demonstrable constitutional commitment” and "judicially discoverable and manageable standards” factors under Baker “are not completely separate; the lack of judicially 'manageable standards may strengthen the -conclusion .that there is a textually demonstrable commitment to ■ a coordinate branch.” Nixon, 506 U.S. at 228-29, 113 S.Ct. 732; see id. at 240, 113 S.Ct. 732 (White, J., concurring) ("[Cjourts are sometimes aided by textual evidence that the Judiciary was not meant to exercise judicial review — a coordinate inquiry; expressed in Balcer's Tack of judicially discoverable and manageable standards’ criterion.”).
     
      
      . Like the parties, the following three factors we find immaterial to the instant case: an inability to resolve the issue without expressing -.a. lack of respect for the ..coordinate branches of government, an unusual need for unquestioning adherence to a political decision already made, and "the potential for embarrassment from multifarious pronouncements by various departments on one question,” Robinson Twp., 83 A.3d at 928.
     
      
      . See supra at 423 & n.13.
     
      
      . While Petitioners, perhaps in an abundance of circumspection, decline to suggest that this Court should abrogate our prior case law, the Law School Professors as Amicus Curiae are not so shy. They argue forthrightly that Mañero //.should be reconsidered and perhaps overruled. Executive Branch Respondents underscore that Petitioners have not taken that strong of a position. Brief for Executive Respondents at 21 & n.8. They correctly note that issues raised only by friends of the Court may not be considered. Id. (citing Mad
        
        ison Const. Co. v. Harleysville Mut. Ins. Co., 557 Pa. 595, 735 A.2d 100, 109 n.8 (1999)). Thus, they effectively contend that Petitioners’ failure to make a frontal attack upon our prior Education Claúse case law forecloses this Court’s ability to consider in this case the soundness and viability of our earlier decisions.
      Respondents are correct to the extent that the question of the ongoing tenability of Dan-son, Marrero II, and the cases upon which they were based is not expressed in the questions as to which we granted review, both of which inquire as to the justiciability of Petitioners’ claims. In reviewing those decisions, though, our final determination as to whether and how they apply to this case requires us to. consider their internal consistency as well as the cogency of their reasoning. Put another way, if, in seeking to harmonize these cases and apply them to the case before us, we find that we cannot do so with due rigor, we cannot look the other way simply because to abrogate prior precedent in the process of resolving this case is more than Petitioners have asked us to do. We would encourage the perpetuation of poorly reasoned ■ precedent were we to permit ourselves to revisit the soundness of our case law only when expressly ihvited to do so based upon a given party’s .tactical, decision of whether to attack adverse case law frontally (always a gamble against long odds) or to attempt more finely to distinguish the adverse decisions. The scope of our review is not so circumscribed. See Freed v. Geisinger Med. Ctr., 607 Pa. 225, 5 A.3d 212, 231 (2010) (noting that testing the validity of the Superior Court’s ruling distinguishing one of our prior cases may entail reviewing the validity of the case in question).
     
      
      . They note that Shenandoah Valley's numbers were so poor in 2013 that, were they to persist, only 36% of students would have graduated high school in the 2016-17 school year. Further, Petitioners allege that Shenandoah Valley’s scores were the highest of all the petitioning school districts. Brief for Petitioners at 36-37.
     
      
      . Respondents’ argument that the General Assembly alone has authority to monitor its own compliance with the Education Clause renders this argument hollow. If Respondents prevail, the General Assembly would be free to defund education entirely without the interference of any other branch of government, subject only to the vicissitudes of the next election cycle. Accordingly, nothing this or any other court does will increase the chance of the proverbial race to the bottom. On the Respondents’ own account, the General Assembly can race to the bottom whenever it chooses for all anyone else can do to interfere.
     
      
      . Presumably, given finite state resources, equalization of expenditures could be achieved only by capping what wealthier districts could spend on their schools. This is precisely what Justice Manderino disputed when he disagreed with the Danson majority that petitioners in that case, sought any particular amount of funding for all districts as a proxy for educational adequacy. See supra n.44.
     
      
      
        .See Petition at 122 ¶ 320 (seeking perma- . nent injunctive relief directing the Commonwealth to "establish, fund, and maintain a thorough and efficient system of public education that provides all students in Pennsylvania with an equal opportunity to obtain an adequate education”).
     
      
      . Whatever definition of thoroughness and efficiency further study might recommend, one must bear in mind the broad array of deficiencies alleged by Petitionérs. Seé Petition at 72-105 (averring, inter alia, teacher shortages and classroom overcrowding, crumbling infrastructure, unavailability of the most basic of learning materials, and so on). It is incorrect to suggest that these reduce to nothing more than á prayer for more money. To the contrary, Petitioners argue consistently that it is the General Assembly’s obligation to give each child an opportunity td obtain an “adequate” education, with the current elaborate matrix of assessments and benchmarks merely indicative that such an opportunity is susceptible of measurement and enforcement.
     
      
      . Challenges to states’ school financing schemes under their education clauses have occurred nationwide over roughly the past forty years, with a broad diversity of results. The scholarly and other literature on this topic is voluminous, and well beyond the scope of this Opinion. However, the following articles would be helpful to a reader seeking more information on the topic: Regina R. Umpstead, Determining Adequacy: . How Courts are Redefining State Responsibility for Educational Finance, Goals, & Accountability, 2007 -B.Y.U, Educ, & L.J.- 281 (2007); John Dayton & Anne Depre,- School Funding Litigation: Who’s Winning the War?, 57 Vand. L. Rev. 2351 (2004); Kelly Thompson Cochran, Beyond School Financing: Defining the. Constitutional Right to an Adequate Education, 78 N.C. L. Rev. 399 (2000), For a Pennsylvania-focused discussion, see Ambrose, supra n.18.
     
      
      . See W.V. Const, art. XII,- § 1;
     
      
      . The Washington Supreme Court:
      “[E]ducation” in its total or ultimate sense .,. comprehends all that series of instruction and discipline which is intended to enlighten • the understanding, correct the temper,-.and form the manners and habits of youth, and fit them for usefulness in the future. In its; most extended signification it may be defined, in reference to man, to be the act of developing and cultivating the various, physical, intellectual,-aesthetic and moral faculties.
      
        Seattle Sch. Dist. No. 1 of King Cnty. v. State, 90 Wash.2d 476, 585 P.2d 71, 94 (1978).
      
        The Tennessee Supreme Court:
      As used in [the Tennessee Constitution], the word 'education' has a definite meaning and needs no modifiers in order to prescribe the precise duty imposed upon the legislature. The first definition of ‘education’ in the unabridged edition of The Random House Dictionary of the English Language, 454 (2d ed. 1987) is: "The act or process of imparting or acquiring general knowledge, developing the powers of reasoning and judgment, and generally of preparing oneself or others intellectually for mature life” .... [The constitutional mandate requires] that the General Assembly shall maintain and support a system of free public schools that provides, at least, the opportunity to acquire general knowledge,
      develop the powers of reasoning and judgment, and generally prepare students intellectually for mature life. ... [TJhis is an enforceable standard for assessing the educational opportunities provided in the several districts throughout the state.
      
      
        Tenn. Small Sch. Sys. v. McWherter, 851 S.W.2d 139, 150 (Tenn. 1993) (emphasis added); cf. Davis v. State, 804 N.W.2d 618, 643 n.37 (S.D. 2011) (allowing that "[l]anguage and its meaning can change with time,” and noting cases in which other courts employed older dictionaries to give meaning to terms relative to when they were employed in law, including Campbell County School District v. State, 907 P.2d 1238, 1258 (Wyo. 1995), which used an 1889 dictionary to define, inter alia, "thorough and efficient").
     
      
      . See Hornbeck, 458 A.2d 758 (implicit finding of justiciability based upon merits review); Skeen v. State, 505 N.W.2d 299 (Minn. 1993) (implicit); Abbott by Abbott v. Burke, 119 N.J. 287, 575 A.2d 359 (1990) (implicit); DeRolph v. State, 78 Ohio St.3d 193, 677 N.E.2d 733 (1997) (explicit rejection of justiciability challenge); Pauley, 255 S.E.2d 859 (implicit); Campbell Cnty. Sch. Dist., 907 P.2d 1238 (implicit); Comm. for Educ'l Rights v. Edgar, 174 Ill.2d 1, 220 Ill.Dec. 166, 672 N.E.2d 1178, 1191-93 (1996) (implicitly deeming justiciable challenge based on claim that "efficient” education required broad-based parity, but deeming non-justiciable claim that system violated distinct "high quality” requirement); see also Brief Amici Curiae of Law Professors at 25-27.
     
      
      . We are not alone in identifying this characteristic as relevant to justiciability. In Connecticut Coalition for Justice, 990 A.2d at 232, the court noted the distinction between states, like Pennsylvapia, that employ qualitative language and those that do not, and found that even words such as “elementary,” "secondary,” and "school” "have a qualitative connotation” rendering the constitutional language less than self-explanatory, and therefore needful of interpretation. Commentators alike have sorted education clauses into discrete categories. See generally Dinan, supra n.ll (relying upon records of various states’ convention debates); Gershon M. Ratner, A New Legal Duty for Urban Public Schools: Effective Education in Basic Skills, 63 Tex. L. Rev. 777, 814-16 (1985) (identifying four "basic groups”: those containing only general education language; those emphasizing the quality of public education (such as Pennsylvania’s “thorough and efficient” requirement); those containing a stronger, more specific mandate; and those stated most strongly, such as the Washington Constitution, which directs that “it is the paramount duty of the state to make ample provision for the education of all children residing within its borders”); William E. Thro, Note, To Render Them Safe: The Analysis of State Constitutional Provisions in Public School Finance Reform Litigation, 75 Va. L. Rev. 1639, 1662-68 (1989) (identifying four categories of education clause).
     
      
      
        . See DuPree v. Alma Sch. Dist. No. 30 of Crawford Cnty., 279 Ark. 340, 651 S.W.2d 90 (1983) (implicitly treating as justiciable clause calling for "general, suitable and efficient system”); Rose, 790 S.W.2d 186 (alluding to justiciability challenge but no express decision rejecting it, in reviewing constitutional provision requiring “efficient system”); Neeley v. W. Orange-Cove Consol. Ind. Sch. Dist., 176 S.W.3d 746 (Tex. 2005) (explicitly rejecting justiciability challenge; "efficient” system). Similarly, various requirements of "liberal,” "quality,” "adequate,” "general,” "thorough,” "common,” and/or “uniform” education systems have been treated as justi-ciable. See Roosevelt Elem. Sch. Dist. No. 66 v. Bishop, 179 Ariz. 233, 877 P.2d 806 (1994) (implicit); Serrano v. Priest, 18 Cal.3d 728, 135 Cal.Rptr. 345, 557 P.2d 929 (1976) (implicit); Lobato v. State, 218 P.3d 358 (Co. 2009) (explicit); Haridopolos v. Citizens for Strong Schools, Inc., 81 So.3d 465 (Fla. Ct. App. 2011), review denied, 103 So.3d 140 (Fla. 2012) (explicit); McDaniel v. Thomas, 248 Ga. 632, 285 S.E.2d 156 (1981) (explicit); Thompson v. Engelking, 96 Idaho 793, 537 P.2d 635 (1975) (implicit); Columbia Falls Elem. Sch. Dist. No. 6 v. State, 326 Mont. 304, 109 P.3d 257 (2005) (explicit); Matthews v. State, 83 Nev. 266, 428 P.2d 371 (1967) (implicit); Leandro, 488 S.E.2d 249 (explicit); Bismarck Pub. Sch. Dist. No. 1 v. State, 511 N.W.2d 247 (N.D. 1994) (implicit); Davis v. State, 804 N.W.2d 618 (S.D. 2011) (explicit, in a parting footnote); Kukor v. Grover, 148 Wis.2d 469, 436 N.W.2d 568 (1989) (implicit). Similarly, the Washington Supreme Court considered the merits of a challenge to its education clause, which established a "paramount duty of the state to make ample provision for the education of all children residing . within its borders.” Seattle Sch. Dist., 585 P.2d 71 (explicit); see Unified Sch. Dist. No. 229 v. State, 256 Kan. 232, 885 P.2d 1170 (1994) (implicit under education clause that provides "[t]he legislature shall provide for intellectual, educational, vocational and scientific improvement by establishing and maintaining public schools”); Comm. for Educ'l Equality v. State, 294 S.W.3d 477 (Mo. 2009) (implicit; clause provides "[a] general diffusion of knowledge and intelligence being essential to the preservation of the rights and liberties of the people, the general assembly shall establish and maintain free public schools”). The Massachusetts Supreme Judicial Court also adjudicated such a challenge, despite its unusually lengthy, diffuse constitutional provision concerning education. See McDuffy v. Sec. of Exec. Office of Educ., 415 Mass. 545, 615 N.E.2d 516 (1993) (implicit); see also Claremont Sch. Dist. v. Governor, 142 N.H. 462, 703 A.2d 1353 (1997) (implicit).
     
      
      . McGary v. Barrows, 156 Me. 250, 163 A.2d 747 (1960) (implicit; clause provides "[i]t shall be [the legislature’s] duty to require[] the several towns to make suitable provision ... for the support and maintenance of public schools”); E. Jackson Pub. Schools, 133 Mich. App. 132, 348 N.W.2d 303 (1984) (implicit; clause provides "[t]he legislature shall maintain and support a system of free public elementary and secondary schools as defined by law”); Pascagoula Sch. Dist. v. Tucker, 91 So.3d 598 (Miss. 2012) (implicit; clause provides "[t]he Legislature shall ... provide for the establishment, maintenance and support of free public schools); Campaign for Fiscal Equity, 769 N.Y.S.2d 106, 801 N.E.2d 326 (implicit; clause provides ”[t]he legislature shall provide for the maintenance and support of a system of free common schools”); Abbeville Cnty. Sch. Dist. v. State, 410 S.C. 619, 767 S.E.2d 157 (2014) (explicit; clause ' provides '"[t]he General Assembly shall provide for the maintenance and support of a system of free public schools”); Tenn. Small Sch. Sys. v. McWherter, 851 S.W.2d 139 (Tenn. 1993) (implicit; clause provides "the General Assembly shall provide for the maintenance, support, and eligibility standards of a system of free public schools”); Brigham v. State, 179 Vt. 525, 889 A.2d 715 (2005) (explicit; clause provides "a competent number of schools ought to be maintained in each town unless the general assembly permits other provisions for the convenient instruction of youth”).
     
      
      . See Ex Parte James, 836 So.2d 813 (Ala. 2002) (finding challenge non-justiciable under education clause expressing the policy of Alabama "to foster and promote the education of its citizens in a manner and extent consistent with its available resources,” which clause specifies that the provision should not be construed to “creat[e] or recognize[e] any right to education . at public expense"); Bonner ex rel. Bonner v. Daniels, 907 N.E.2d 516 (Ind. 2009) (finding challenge non-justiciable under education clause requiring "general and uniform” education); Okla. Educ. Ass'n v. State ex rel. Okla. Legislature, 158 P.3d 1058 (Okla. 2007) (finding challenge non-justiciablc under constitution requiring establishment and maintenance of "a system of free public schools”); City of Pawtucket v. Sundlun, 662 A.2d 40 (R.I. 1995) (finding challenge non-justiciable under clause directing general assembly "to adopt all means which it may deem necessary and proper to secure to the people the advantages and opportunities of education”); cf. Comm. for Educ'l Rights v. Edgar, 174 Ill.2d, 1, 220 Ill.Dec. 166, 672 N.E.2d 1178 (1996) (distinguishing between education clause challenges based upon nor-matively adequate education and disparities in funding from one based upon claim concerning whether state educational institutions were "high quality,” and deeming only the last of these to be non-justiciable).
      Notably, a majority of states whose courts have found education clause challenges non-justiciable have education clauses that contain the sort of facial textual commitment of self-monitoring that we find absent in our own Education Clause, For example, the Oregon Constitution, in Article VIII, Section 8, directs the state assembly to appropriate “a sum of money sufficient to ensure that the state's system of public education meets quality goals established by law" (emphasis added). The Virginia Constitution, in Article VIII, Section 1, directs its assembly to "provide for a system of free public elementary and secondary schools ..., and shall seek to ensure that an educational program of high quality is established and continually maintained,” and, in Section 2, specifies that “[sjtandards of quality for the several school divisions shall be determined and prescribed from time to time by the Board of Education, subject to revision only by the General Assembly" (emphasis added). The Rhode Island Constitution provides that "it shall be the duty of the general assembly to promote public schools and public libraries, and to adopt all means which it may deem necessary and proper to secure to the people the advantages and opportunities of education and-public library services.” R.I. Const, art. XII, § 1 (emphasis added), These suggest precisely the sort of textual commitment that might satisfy the Robinson Township requirement that the textual commitment include not only a mandate but also evidence that the framers intended the legislature to monitor its own compliance with that mandate.
     
      
      . Noting the dearth of jurisprudence interpreting the Environmental Rights Amendment, -a plurality of justices in Robinson Township emphasized that, nonetheless, "this Court has an obligation to vindicate the rights of its citizens ... in accordance with the plain language of the constitution.” Robinson Twp., 83 A.3d at 969. We also observed that ”[t]he [interpretive] task is neither more nor less intrusive upon a coordinate branch function than in other matters in which we are called upon to determine the constitutional validity of a legislative act.” Id. at 929.
     
      
      . It is not lost on this Court that this "reasonable relationship” terminology -closely tracks that of the "reasonable relation” test invoked, if opaquely employed, by this Court in the Teachers' Tenure Act Case, Danson, and Marrero II.
      
     
      
      . To the extent that their Petition read as a whole creates any ambiguity on this point, we emphasize that it is our obligatión to read the Petition in the light most favorable to Petitioners’ claims.
     
      
      , The parties once again focus upon the first three Baker factors. See supra n.47.
     
      
      . No political question challenge was raised or addressed in Rodriguez. However, in federal courts, unlike in Pennsylvania courts, see supra at 436-38, the question of justiciability, and specifically the political question doctrine, goes to the jurisdictional "case or controversy” requirement set forth in Article III of the United States Constitution. See Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 215, 94 S.Ct. 2925, 41 L.Ed.2d 706 (1974). Thus, the absence of discussion of the issue does not make less significant the Court’s assertion of jurisdiction over the Equal Protection Clause claim.
     
      
      . This is consistent with the intuition that to disregard the beneficiaries of a mandate is to render that mandate little more than a hortatory slogan. But this intuition is by no means shared by all. Compare Wesley Hohfeld, Some Fundamental Conceptions as Applied in Judicial Reasoning, 23 Yale LJ. 16, 32 (1913) (distinguishing rights from privileges, and observing that " ‘[djuty’ and 'right' are correla-five terms”); McDuffy v. Sec. of Exec. Office of Educ., 415 Mass. 545, 615 N.E.2d 516, 527 n.23 (1993) (“[I]f ‘legislatures and magistrates’ have a constitutional duty to educate, then members of the Commonwealth have a correlative constitutional right to be educated.”); Seattle Sch. Dist. No. 1 of King Cnty. v. State, 90 Wash.2d 476, 585 P.2d 71, 91 (Wash. 1978) (noting state's “paramount duty to make ample provision” for education, with the result that "all children residing within the [state] possess a ‘right’ arising from the constitutionally imposed ‘duty’ of the [s]tate”) with Scott R. Bauries, The Education Duty, 47 Wake Forest L. Rev. 705, 706 (2012) (rejecting the proposition that individual rights arise as a necessary corollary of constitutional mandates imposed upon legislatures, and arguing in favor of analyzing legislative compliance with a given mandate as a question of fiduciary duty, “using the tools of deference appropriate to the review of discretionary decisions by individuals in positions of trust”).
     
      
      . See Serrano v. Priest, 18 Cal.3d 728, 135 Cal.Rptr. 345, 557 P.2d 929, 951-52 (1976) ("fundamental interest” in education under provision requiring "a system of common schools by which free school shall be kept up and supported”); Horton v. Meskill, 172 Conn. 615, 376 A.2d 359, 373-74 (1977) (fundamental right where constitution provides "[t]here shall always be free public elementary and secondary schools'in the state”); Rose v. Council for Better Educ., Inc., 790 S.W.2d 186, 201 (Ky. 1989) (fundamental right to education where constitution directs the assembly to "provide for an efficient system of common schools”); McDuffy v. Sec. of Exec. Office of Educ., supra n.68; Claremont Sch. Dist. v. Governor, 142 N.H. 462, 703 A.2d 1353, 1358-59 (1997) (fundamental right based upon "the fact that [the] State Constitu- ■ tion specifically charges the legislature with the duty to provide public education” and "to cherish the interest of ... public schools”); Leandro, 488 S.E.2d at 255 (framers intended to establish "a fundamental right to sound basic education” where -education clause states that "[t]he people have a right to the privilege of education”); Bismarck Pub. Sch. Dist. No. 1 v. State, 511 N.W.2d 247 (N.D. 1994) (fundamental right under provision directing “a uniform system of free public schools”); Kukor v. Grover, 148 Wis.2d 469, 436 N.W.2d 568, 579 (1989) (fundamental right under provision directing establishment of public schools that are "as nearly uniform ' as practicable”); cf. Roosevelt Elem. Sch. Dist. No. 66 v. Bishop, 179 Ariz. 233, 877 P.2d 806 (1994) (noting inconsistencies in prior cases' applying rational basis to so-called "fundamental right" but declining to determine whether such a right inhered under ■ Arizona Constitution in that case); DuPree v. Alma Sch. Dist. No. 30 of Crawford Cnty., 279 Ark. 340, 651 S.W.2d 90, 93 (1983) (alluding to a right, but declining to determine whether it is fundamental because funding scheme did not pass rational basis review); Tenn. Small Sch. Sys. v. McWherter, 851 S.W.2d 139 (Tenn. 1993) (a "right to a free public education”); Neeley v. W. Orange-Cove Consol. Ind. Sch. Dist., 176 S.W.3d 746, 784-85 (Tex. 2005) (rejecting fundamental right formula„tion and rational basis as well, holding that "[i]f the Legislature’s choices are informed by guiding rules and principles properly related to public education — that is, if the choices are not arbitrary — then the system does not violate the constitutional provision"); Seattle Sch. Dist. No. 1 of King Cnty. v. State, supra n.68. But see McDaniel v. Thomas, 248 Ga. 632, 285 S.E.2d 156, 167 (1981) (no fundamental right where constitution requires provision of an "adequate public education for the citizens”); Thompson v. Engelking, 96 Idaho 793, 537 P.2d 635 (1975) (no fundamental right where constitution directs legislature to “establish and maintain a general, uniform and thorough system of public, free common schools”); Bonner ex rel. Bonner v. Daniels, 907 N.E.2d 516, 522 (Ind. 2009) (no right to education whatsoever); Unified Sch. Dist. No. 229 v. State, 256 Kan. 232, 885 P.2d 1170, 1189-90 (1994) (no fundamental right under constitutional provision requiring establishment and maintenance of public schools); Committee for Educ'l Rights v. Edgar, 174 Ill.2d 1, 220 Ill.Dec. 166, 672 N.E.2d 1178, 1194-95 (1996) (no fundamental right under requirement of "efficient system of high quality public educational institutions and services”); Hornbeck, 458 A.2d at 786 (no fundamental right but noting "Maryland’s Constitution explicitly, not to mention implicitly, guarantees rights and interests which can in no way be considered ‘fundamental’ ’’); East Jackson Pub. Schools v. State, 133 Mich. App. 132, 348 N.W.2d 303, 305 (1984) (no fundamental right under provision requiring legislature to “maintain and support a system of free public elementary and secondary schools as defined by law”); Committee for Educ’l Equality v. State, 294 S.W.3d 477, 490-91 (Mo. 2009) (no fundamental right under provision requiring "free public schools for ... gratuitous instruction”); City of Pawtucket v. Sundlun, 662 A.2d 40 (R.I. 1995) (no fundamental right where constitution required legislature "to promote public schools ..., and to adopt all means which it may deem necessary and proper to secure to the people the advantages and opportunities of education”).
     
      
      . Some state courts inteipreting constitutional provisions requiring the legislature to provide a "thorough and efficient” system of public schools have found an implicit, fundamental right. See Skeen v. State, 505 N.W.2d 299 (Minn. 1993); Pauley, 255 S.E.2d 859; Campbell County School District v. State, 907 P.2d 1238, 1257-58 (Wyo. 1995).
     
      
      . Baker v. Carr, 369 U.S. 186, 82 S.Ct. 691, 7 L.Ed.2d 663 (1962).
     
      
      . The Education Clause provides: “The General Assembly shall provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth.” PA. CONST, art. Ill, § 14.
     
      
      . In relevant part, Article III, Section 32 of the Pennsylvania Constitution prohibits the General Assembly from enacting special or local laws regulating the affairs of school districts that can be provided for by general law. »PA. CONST, art. Ill, § 32, .Pennsylvania courts consider Article III, Section 32 and the Equal Protection Clause of the United States Constitution, U.S. CONST, amend. XIV, § 1, to be equivalent as both command that like persons in like circumstance be treated similarly. Harrisburg Sch. Dist. v. Zogby, 574 Pa. 121, 828 A.2d 1079, 1088 (2003) (citations omitted).
     
      
      . As the Petition was dismissed on a demurrer, the facts as summarized below are drawn from it and developed favorably to Plaintiffs. See Gresik v. PA Partners, 613 Pa. 303, 304 n.1, 33 A.3d 594, 595 n.1 (2011). We accept all well-pleaded facts in the Petition and all reasonable inferences drawn from them. See Small v. Horn, 554 Pa. 600, 608, 722 A.2d 664, 668 (1998).
     
      
      . The Board is the Department’s regulatory and policy-making entity for basic and higher education. It adopts standards to facilitate improved student achievement and issues reports and recommendations giving guidance to the governor and school districts. See 24 P.S. § 26-2603-B; 22 Pa. Code § 4.2.
     
      
      . The Education Clause first appeared substantially in its present form in the 1874 Constitution, at which time it directed the Legislature to “provide for the maintenance and support of a thorough and efficient system of public schools, wherein all the children of this Commonwealth above the age of six years may be educated, and [to] appropriate at least one million dollars each year for that purpose.” PA. Const, art. X, § 1 (1874).
     
      
      . Section 32 prohibits local or special laws in cases that can be provided for by general laws, and it expressly precludes local or special laws regulating the affairs of school districts. This Court has stated that Section 32 is substantially coterminous with the federal Equal Protection Clause. See Balt. & Ohio R. Co. v. Dep't of Labor & Indus., 461 Pa. 68, 83, 334 A.2d 636, 643 (1975). In this opinion, all subsequent references to the Equal Protection Clause pertain to Article III, Section 32, unless otherwise noted.,
     
      
      . See also Majority Opinion, at 432 n.28 (enumerating the Baker factors and observing that the presence of any one factor is sufficient for abstention under the political question doctrine).
     
      
      . The City of Philadelphia, as well as several individuals and organizations have filed ami-cus briefs supporting Plaintiffs’ position, including: the Philadelphia Federation of Teachers, Local 3, of the American Federation of Teachers, AFL-CIO, together with the American Federation of Teachers Pennsylvania AFT, AFL-CIO; two separate groups of youth, education, and civil rights advocacy associations led, respectively, by Public Citizens for Children and Youth and the Consortium for Public Education; and a group of individual law professors.
     
      
      . Generally, only the first three Baker factors are at issue in Education Clause cases.
     
      
      . The Legislative Defendants fault Plaintiffs for allegedly attempting to change the issue to whether the funding scheme bears a reasonable relation to providing students with an opportunity to meet state standards, rather than providing for the maintenance and support of .a thorough and efficient system of public schools, See Brief for Legislative Appel-lees at 12 n.6. In light of the treatment of the "reasonable relation” standard below, any such distinction is immaterial to the present appeal.
     
      
      . Act of Mar, 10, 1949, P.L. 30 (as amended 24 P,S. §§, 1-101 to 27-2702),(the "School Code”).
     
      
      . The political question doctrine is one of several that "have evolved to give body to the general notions of case or controversy and justiciability.” Rendell v. Pa. State Ethics Comm'n, 603 Pa. 292, 307, 983 A.2d 708, 717 (2009). Others include standing,- ripeness, and mootness'. See id. '
      
     
      
      . See also Pa. Ass'n of Rural & Small Schs. v. Ridge, No. 11 M.D. 1991, slip op. at 118 n.70 (Pa. Cmwlth. July 9, 1998) (“PARSS”) (single-judge opinion) (observing that the judiciary's reluctance to involve itself in the public school system "has a long history” (citing Wharton v. Cass Twp. Sch. Dirs., 42 Pa. 358, 364 (1862))), aff'd per curiam, 558 Pa. 374, 737 A.2d 246 (1999), reprinted in Brief for Appellants at Addendum B.
      The PARSS case and the Marrero litigation raised similar issues, and PARSS was also substantively similar to the present matter in that it raised Education Clause and Equal Protection Clause claims based pn disparities in school funding. The Commonwealth Court in PARSS held a four-week trial, but it ultimately dismissed the claims as non-justiciable based on the intervening decision in Marrero I. This Court summarily affirmed PARSS the same day it decided Mañero II.
      
     
      
      . Although the Education Clause places obligations upon the Legislature, school districts (which are legislatively created), including their governing boards, comprise an important means by which that body fulfills such obligations.
     
      
      . This description of Danson as constituting the first Education-Clause-based challenge is in tension with the majority’s suggestion that Teachers' Tenure Act “implicitly and necessarily treat[ed] a claimed violation of the Education Clause as justiciable.” Majority Opinion, at 445. Notably, Teachers’ Tenure Act relied on the broad authority given to the legislative branch under the Education Clause as a basis for concluding that that branch remained free to alter education statutes in the future. As such, Teachers’ Tenure Act does not constitute precedent indicating that the type of claim asserted here — dealing with the Legislature’s alleged failure to fulfill its affirmative obligations under the Education Clause — is justiciable. See infra note 18.
     
      
      . See PARSS, No. 11 M.D. 1991, slip op. at 98-100, 103-04 (discussing the proposed uniformity requirement and describing that the delegates at the 1873 Constitutional Convention rejected it in favor of a 'flexible system adaptable to the diverse local needs and conditions of Pennsylvania’s school districts (citing and quoting II Debates of the Convention To Amend the Constitution of Pennsylvania 419-26(1873))).
     
      
      . My conclusion in this regard is limited to the issue of justiciability and should not be understood as suggesting the Education Clause is permissive rather than mandatory.
     
      
      
        . See generally Danson, 484 Pa. at 427, 399 A.2d at 366 ("It must indeed be obvious that the same total educational and administrative expenditures by two school districts do not necessarily produce identical educational ser- ■ vices. The educational product is dependent upon many factors, including the wisdom of the expenditures as well as the efficiency and economy with which available resources are -utilized.”).
     
      
      . Plaintiffs contend it is unrealistic to suppose the legislative body would lower or eliminate statewide standards “to avoid its constitutional obligations." Reply.Brief for Appellants at 13 n.8. Plaintiffs overlook that the Legislature may do so to free itself from judicial oversight as it attempts to fulfill its obligations, or that it may. ultimately conclude as a policy matter that standardized testing is counterproductive. See Lisa Kelly, Yearning for Lake Wobegon: The Quest for the Best Test at the Expense of the Best Education, 7 S. Cal. Interdisc. L.J. 41, 42, 64-79 (1998) (arguing that a focus on standardized test results harms educational outcomes and deepens racial and class differences in academic achievement).
     
      
      . By assigning a duty to the General Assembly, the Education Clause "both empowers and obligates.” Neeley v. W. Orange-Cove Consol. Indep. Sch. Dist., 176 S.W.3d 746, 778 (Tex. 2005) (internal quotation marks and citation omitted).
     
      
      . See also United States v. Clark, 435 F.3d 1100, 1114 (9th Cir. 2006) (same as to Commerce Clause); SEPTA v. PUC, 826 F.Supp. 1506, 1520-21 (E.D. Pa. 1993) (same); cf. Wisconsin v. City of N.Y., 517 U.S. 1, 19, 116 S.Ct. 1091, 1101, 134 L.Ed.2d 167 (1996) (evaluating whether administrative action was constitutional by asking whether it was reasonably related Congress's constitutionally-conferred authority).
     
      
      . Article I, Sections 1 and 26 .have been identified as constituting the other equal protection provisions of the Pennsylvania Constitution. See Klein v. SERS, 521 Pa. 330, 344-45, 555 A.2d 1216, 1223 (1989). Here, however, Plaintiffs rely only on Article III, Section 32.
     
      
      . Under strict scrutiny a classification must be narrowly tailored to a compelling state interest. See D.P. v. G.J.P., 636 Pa. 574, 584, 146 A.3d 204, 210 (2016). Classifications which are “quasi-suspect” (sometimes referred to as "sensitive”), trigger an intermediate level of review in which the classification must be substantially related to an important government interest. See Commonwealth v. Bell, 512 Pa. 334, 344-45, 516 A.2d 1172, 1178 (1986) (summarizing the three levels of scrutiny under Pennsylvania law).
     
      
      . This list is not meant to be exclusive.
     
      
      . I do not mean to suggest that any and .all burdens upon Article I rights must be justified by a compelling state interest. See generally Robinson v. Cahill, 62 N.J. 473, 303 A.2d 273, 282 (1973) (criticizing the concept that the burdening of fundamental rights as defined in Rodriguez should always invoke strict scrutiny).
     
      
      . As the Executive Defendants observe, individual rights in education were not at issue in Wilkinsburg. The underlying dispute related to whether a school board could contract with a private company .to .operate a school. The issue directly before the Court was whether an evidentiary hearing was needed before a preliminary injunction could issue in favor of the plaintiff union. A responsive opinion which garnered majority support clarified that, per the doctrine of constitutional avoidance, the Court's ruling was limited to remanding for such a hearing so that any statutory or constitutional questions which may arise could be resolved by the common pleas court on a developed record. See Wilkinsburg, 542 Pa. at 346, 667 A.2d at 10 (Zappala, J., concurring). Finally, the only purpose served by the majority's sua< sponte declaration that education is a fundamental right was to bolster its directive that, on remand, the best interests, of the students should serve as the polestar of the county court's ultimate decision as to whether to grant the union's request for a preliminary injunction. ,
     
      
      . Accord, e.g., Lujan v. Colo. State Bd. of Educ., 649 P.2d 1005, 1016-19 (Colo. 1982); McDaniel v. Thomas, 248 Ga. 632, 285 S.E.2d 156, 166-67 (1981); Bd. Of Educ. of Cincinnati Sch. Dist. v. Walter, 58 Ohio St.2d 368, 390 N.E.2d 813, 817-19 (1979); cf. Kukor v. Grover, 148 Wis.2d 469, 436 N.W.2d 568, 579 (1989) (determining that an "equal opportunity for education" is a fundamental right under the state’s education clause, but holding that the state’s education funding system was subject to rational basis review); Skeen v. State, 505 N.W.2d 299, 313 (Minn. 1993) (similarly finding that education is. a fundamental right under the state charter and, while strict scrutiny should apply "in determining whether the legislature has met a student’s fundamental right to a general and uniform system of public schools, a lesser standard, such as a rational basis test, should apply to the determination of whether the financing of such a system is 'thorough and' efficient.'''). But see, e.g., Washakie Cnty. Sch. Dist. No. 1 v. Herschler, 606 P.2d 310, 333-35 (Wyo. 1980) (expressing that because education is a fundamental' right under the state constitution, the government's funding scheme must satisfy strict scrutiny); Pauley v. Kelly, 162 W.Va. 672, 255 S.E.2d 859, 878 (1979) (same); Seattle Sch. Dist. No. 1 of King Cnty. v. State, 90 Wash.2d 476, 585 P.2d 71, 91 (1978) (same where the state- charter prioritized education over other legislative obligations by expressly making it the legislature's -"parámount duty”).
     
      
      . Plaintiffs argue that the General Assembly is to blame for the additional reason that that body draws school district boundaries and decides what types of properties, business transactions, and services may be locally taxed. See Petition 1Í289. The Supreme Court has "rejected an identical argument. See Rodriguez, 411 U.S. at 53-54, 93 S.Ct. at 1307 (noting that the existence of local government units requires the drawing of arbitrary boundaries, and the amount of taxable wealth within those boundaries will invariably differ, fluctuate, and depend on the decisions of actors other than state officials, including local officials, local residents, and private enterprises).
     
      
      . See Danson, 484 Pa. at 427, 399 A.2d at 367; see also Wright v. Council of City of Emporia, 407 U.S. 451, 469, 92 S.Ct. 2196, 2206, 33 L.Ed.2d 51 (1972) ("Direct control over decisions vitally affecting the education of one's children is a need that is strongly felt in our society[.]”); Papasan v. Allain, 478 U.S. 265, 284-85, 106 S.Ct. 2932, 2943-44, 92 L.Ed.2d 209 (1986) (acknowledging the state has a rational interest in accommodating two separate forces via a funding system involving local and state elements: society’s desire that all children receive an education, and parents' desire that their own children receive the best affordable education); Rodriguez, 411 U.S. at 51-53 & n.109, 93 S.Ct. at 1306-07 & n.109 (explaining how local funding allows for the retention of local decision-making). See generally Rodriguez, 411 U.S. at 48-51 & nn. 102-08, 93 S.Ct. at 1304-06 & nn. 102-08 (discussing the history and importance of local decision-making in the public-education arena!).
     
      
      . PA. Const, art. Ill, § 14.
     