C-013
K-12 and student-aid analysis is constrained by legal collection limits and eligibility structure
Section 11 treats missing education spending ledgers as a real transparency limit rather than something to impute.
Sources
S-069
Section 11 - Version 1.0 LOCKED
Education / Public Services
Legal and eligibility structure for K-12 and student-aid analysis where status spending is not cleanly published.
Audit contents — Section 11
Structured Verification
Trace this section from the data model.
Summary: Legal and eligibility structure for K-12 and student-aid analysis where status spending is not cleanly published.
Claims: 1
Claim links: C-013
Claims In This Section
Reviewers should be able to move from section to claim without leaving the generated evidence path.
11.K Key Findings
- K-12 is constitutionally status-blind under Plyler v. Doe: schools may not collect immigration status, so no federal-by-status breakout can exist and the matter routes to Section 13 under A-032. Most K-12 funding is state and local, with the federal share around 8-10%.
- Undocumented students are barred from federal student aid at $0; eligible-noncitizen aid is not published by status and routes to Section 13 under A-033.
11.1 Primary facts
Plyler v. Doe (1982) requires free K-12 education regardless of status and prevents schools from collecting immigration status. The federal K-12 share is mainly Title I, IDEA, and Title III. Title IV requires citizen or eligible status, so undocumented persons are barred from FAFSA and federal aid, while lawful permanent residents, refugees, and asylees may qualify. Head Start, adult programs, and career-technical services have historically been status-neutral, though recent 2025 federal policy restricted undocumented access in some areas.
11.2 Treatment
- Federal K-12 share for non-citizen students, including Title I, IDEA, and Title III, routes to Section 13 under A-032 because status is never collected and any figure would be fabrication. The absence is itself the finding.
- Federal student aid: undocumented equals $0 by exclusion; eligible-noncitizen aid is not cleanly published by status and routes to Section 13 under A-033.
- Head Start, public health, library, and emergency services are mostly status-neutral or state/local and therefore route to Section 13 or are excluded as U.S. operations.
11.3 Total A vs Total B
Total A is not isolable from primary evidence and routes to Section 13. Total B likewise runs through school districts and institutions as the paying entities.
11.4 Excluded
State and local K-12 funding is excluded as non-federal. Undocumented federal student aid is $0. General public services are excluded where they are state/local or U.S. operations. Advocacy figures describing the “cost of educating undocumented students” are modeled state/local estimates and are excluded under the no-modeling rule.
11.HR Hostile review
“K-12 cost of undocumented students is widely estimated.” This does not land. Those estimates are state/local and modeled, while the federal share by status is legally uncollectable under Plyler. The audit refuses modeled state figures by rule. The section survives hostile review.
11.QA / LOCK
The Plyler legal bar is preserved; undocumented federal student aid remains $0; eligible-noncitizen aid routes to Section 13; provider capture by districts and institutions is identified. Section 11 is locked in Version 1.0.