Section 5 of Article IX of the State of California Constitution guarantees students a “free public education.” The State Supreme Court concluded in the 1984 case of Hartzell v. Connell, “that all educational activities carried on by public school districts, extra-curricular as well as curricula, must be without cost to the students who participate in such activities.” This same ruling found that “mandatory fees for participating in such extra-curricular activities as drama, music, and athletic competition were illegal under the State Constitution.” Furthermore, they also rejected the argument that “fees could be charged so long as the district waived fees for students who were financially unable to pay.” Recent proposed legislation includes reimbursement with interest for any illegally-collected fees as well as a district sanction.