Baker v. Hudson School District

269 A.2d 128, 110 N.H. 389, 1970 N.H. LEXIS 179
CourtSupreme Court of New Hampshire
DecidedAugust 31, 1970
Docket6115
StatusPublished
Cited by3 cases

This text of 269 A.2d 128 (Baker v. Hudson School District) is published on Counsel Stack Legal Research, covering Supreme Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baker v. Hudson School District, 269 A.2d 128, 110 N.H. 389, 1970 N.H. LEXIS 179 (N.H. 1970).

Opinion

Kenison, C.J.

Petition for a temporary and permanent injunction brought by the plaintiffs, a six-member majority of the Hudson Budget Committee, against the Hudson School District, its school board and chairman, and die Superintendent of Schools. The petition seeks to enjoin the defendants from expending any money or incurring liabilities on matters included in the appropriation made for the support of schools at die April 29, 1970 meeting of the school district, pending a determination of the validity of the appropriation.

At die hearing on the petition for temporary injunction the Superior Court {Leahy, C.J.) on an agreed statement of facts reserved and transferred to die supreme court widiout ruling all questions of law relating to die validity of the actions of the Budget Committee of the Town of Hudson and the validity of the actions taken at die special meeting of the Hudson School District held on Aprd 29, 1970 pursuant to a school board request granted by die superior court. RSA 197:3.

The case was filed in the supreme court on August 11, 1970. The briefs of the parties were submitted on August 11 and August 27, 1970.

The question in this case is whether the legislature in granting authority under the Municipal Budget Law ( RSA 32:8 ( supp ) and 9) to die voters at an annual or special meeting to increase the budget by not more than 10% of the total amount specified in the budget recommended by the Budget Committee, intended diat the voters at the meeting (widiin the limitations imposed by statute) share the responsibility widi the Budget Committee *391 in appropriating funds by exercising a judgment independent of and unfettered by the judgment of the Budget Committee as to what the maximum total budget shall be. For the reasons stated hereafter we diink the answer to this question is “ yes. ”

The Budget Committee majority recommended a smaller school budget than requested by the School Board. The majority of the Budget Committee in its report stated that they “ are of the honest opinion that the budget present, $1,760,000.00, with the allowable increase of $176,000.00, is a fair and just budget and urge the School District voters to adopt said budget with the increase. ” (Emphasis added). The budget recommendations did not rec - ommend sufficient funds to pay fully statutory obligations, such as the payment of principal on debt. The recommendations of the Budget Committee had been rejected decisively by the voters at the annual school district meeting on March 4, 1970 by a vote of 301 to 155, and were again rejected at the special meeting on April 29, 1970 by a vote of 230 to 105.

After rejecting the Budget Committee’s recommendation of the total budget of $ 1,936,000 ( $ 1,760,000 + 10% ) the voters adopted a total budget of $1,932,000 with the understanding that the Tax Commission would add $ 170,055, which was the amount owed for the payment of principal debt. This resulted in a total appropriation of $2,102,055. This was a valid appropriation, as it was within the amount authorized by RSA 32:9 on these facts and was within the total budget figure provided as a maxi - mum figure in the warrant posted for the special school district meeting of April 29, 1970,

The present controversy arises from a common problem. A school board is charged with managing a local school system to the best of its ability. Since almost every improvement costs money, there is an increasing burden on the local taxpayer. This same taxpayer must also support other municipal services with each department attempting to increase its budget to perform as well as possible. An arbiter, such as the Budget Committee, is given power by the legislature to reconcile these appropriation requests to maintain the tax load within manageable proportions.

Some jurisdictions, apparently fearing the penurious nature of officials unfamiliar with school requirements, have given the school board the final say on the size of appropriations. See Day v. City of Newton, 342 Mass. 568, 174 N.E.2d 426. Other jurisdictions have given a supervisory committee the final say as *392 to the size of the appropriation but left the distribution of the appropriation entirely within the hands of the school board. See Board of Education v. Board of Finance, 127 Conn. 345, 16 A.2d 601; Fowler v. Town of Enfield, 138 Conn. 521, 86 A.2d 662; Board of Education v. Rogers, 278 N.Y. 66, 15 N.E.2d 401. Some jurisdictions provide for appeal to a state education commission to settle such disputes. Cliffside Park Borough Bd. of Ed. v. Mayor & Council, 100 N.J. Super. 490, 242 A.2d 649.

“‘In any particular instance the degree of control to be exercised by either schoolboard members or municipal officers must be ascertained by reference to statutory and charter provisions. Under no circumstances, however, will municipal officers be permitted to exercise any greater degree of control over school finance than that clearly intended by the legislature. ’ Edwards, The Courts and Public Schools 106 (rev. ed. 1955 ). In New Hampshire die extent to which school finances are subject to municipal control in each city is determined by its charter. Toussaint v. Fogarty, 80 N.H. 286; Wilcox v. Burnham, 98 N.H. 64, 65.” Franklin v. Hinds, 101 N.H. 344, 345-46, 143 A.2d 111, 113.

The New Hampshire cases have recognized a policy favoring financial independence for school districts wherever possible. Nashua Board of Education v. Vagge, 102 N.H. 457, 159 A.2d 158. This is in line with the recommendations of the Report of the [Legislative] Commission to Study the State Education System (1946) quoted in Franklin v. Hinds, supra at 346, 143 A.2d at 113; “The kind of education the district wants to buy, for it comes down to just that, had better be the responsibility of their elected representatives, the school board, and the people of the district themselves. ” ( Emphasis added).

RSA 32:4 through 32:9 evidences a legislative scheme to allow the voters, who must bear the burden of taxation, to override the judgment of the Budget Committee by appropriating up to 10% more than the Budget Committee honestly believes is appropriate. Although the Budget Committee does put an upper limit on appropriations, it should also function as an information agency with special fiscal knowledge to assist the electorate in voting intelligently on budget problems. Hecker v. McKernan,

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Related

Board of Selectmen v. School Board of Pittsfield School District
311 A.2d 124 (Supreme Court of New Hampshire, 1973)
Laconia Board of Education v. City of Laconia
285 A.2d 793 (Supreme Court of New Hampshire, 1971)
Ashley v. Rye School District
274 A.2d 795 (Supreme Court of New Hampshire, 1971)

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Bluebook (online)
269 A.2d 128, 110 N.H. 389, 1970 N.H. LEXIS 179, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baker-v-hudson-school-district-nh-1970.