The New Hampshire Supreme Court sent an education-funding lawsuit brought by a number of local school districts back to the Cheshire County Superior Court, saying the lower court did not use the proper legal analysis when it declared the state’s school-funding formula unconstitutional as applied to these districts. Coontoocook Valey Sch. Dist. v. State. [New Hampshire Decision], In June, 2019, Cheshire County Superior Court Judge David Ruoff had held that the New Hampshire’s current per-pupil funding levels are “unconstitutional as applied to the Petitioning school districts,” and that the state legislature must re-analyze the actual cost of providing New Hampshire students an adequate education.
Judge Ruoff had granted the plaintiffs’ motion for summary judgment on the grounds that the relevant budget appropriations were unconstitutional, after analyzing the cost determinations and rationales reflected in the legislature’s Joint Committee’s Final Report and 2008 Spreadsheet. He found that these documents utilized insufficient teacher-student ratios and insufficient transportation costs. The Supreme Court’s unanimous decision held that the lower court had relied on “legislative history,” rather than the actual text of the relevant state statute, and that the judge failed to take into account other information that the Legislature may have considered in determining the actual appropriations for these districts.
The Court further held, however, that the plaintiffs had a right to a full evidentiary hearing on their general claim that the actual amounts determined by the legislature have failed to meet its obligation to fully fund an adequate education as required by Part II, Article 83, of the New Hampshire Constitution:
“We agree that resolving this fact-driven dispute is a prerequisite for determining whether the amount of funding set forth in [the statue setting the funding formula] is sufficient to deliver the opportunity for an adequate education.”
Accordingly, the Supreme Court sent the case back to the trial court for further proceedings consistent with the high court’s ruling.