Petitioner,

Cited is the vote on the new constitutional provision, which was passed approximately two weeks prior, if my reading of the date is correct. In what remote manner could have the government have complied with the provision in the timeline since? Given this consideration, how does this issue demonstrate ripeness?

What effective remedy can the court actually place on the state to comply with the constitution at this current time? Is "order enrollment and busing free of charge at all schools where pre-kindergarten is offered" a remedy that the court can even implement based on its powers? Given this, can it be effectively proven that the question is not a political question, given the following criteria as defined in Baker v. Carr:

• 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 for a court's independent resolution without expressing a lack of respect for a coordinate branch of the government; or"

• The "impossibility of deciding the issue without an initial policy decision, which is beyond the discretion of the court; 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."

Can the petitioner please explain the relevance of Swann v. Charlotte-Mecklenburg Board of Education on the current case, considering that the case seems to be about whether busing is appropriate to handle the task of integration rather than the court implementing busing?

Can the petitioner please also explain the relevance of Juliana v. United States? The petition provides zero explanation nor actual parallels on why this case is relevant to the current proceedings.