Relying substantially on a prior adequacy decision of the Rhode Island Supreme Court, the state superior court earlier this month granted the state’s motion to dismiss the complaint in Woonsocket Sch. Comm et al v. Chafee. The lower court extensively cited the state Supreme Court’s 1995 decision in City of Pawtucket v. Sundlun, 662 A. 2d 40, in which the high court had dismissed a prior adequacy suit. The Court held there that adequacy claims are not justiciable and that the Rhode Island Constitution grants the General Assembly exclusive responsibility over public education in the state.
Plaintiffs sought to distinguish Sundlun in two ways. First, they argued that over the past 15 years, the state’s General Assembly and the state education department have adopted detailed academic standards and have imposed numerous obligations on local school districts to provide meaningful educational opportunities for all students, but that they have failed to provide adequate or equitable funding to allow the districts to carry out these obligations. Second, they claimed that constitutional changes adopted in 2004 eliminated the General Assembly’s plenary authority over public education.
The Court rejected the first argument by holding that education is not a fundamental interest under the Rhode Island constitution; accordingly, only the rational basis test which calls for minimal judicial scrutiny of legislative actions would be applied. It further ruled that the constitutional amendments of 2004 did not undermine the strong separation of powers bent of the Rhode Island constitution, and cited an advisory opinion of the Supreme Court which it read to indicate that the 2004 changes would not affect the plenary powers of the General Assembly over education. Plaintiffs intend to appeal directly to the state supreme court and to ask the court for a definitive ruling on these issues.
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