Manchester v. Crisman, et al.

2001 DNH 138
CourtDistrict Court, D. New Hampshire
DecidedJuly 31, 2001
DocketCV-97-632-M
StatusPublished

This text of 2001 DNH 138 (Manchester v. Crisman, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Manchester v. Crisman, et al., 2001 DNH 138 (D.N.H. 2001).

Opinion

Manchester v. Crisman, et a l . CV-97-632-M 07/31/01 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

City of Manchester School District, Plaintiffs

v. Civil No. 97-632-M Opinion No. 2001 DNH 138 Margaret Crisman, as Surrogate Parent for Kimberli M . , and the Town of Pittsfield School District, Defendants

O R D E R

In its Order dated March 26, 2001, the court considered

cross-motions for summary judgment, analyzed what it considered

to be the dispositive issues and applicable law, and invited

Manchester School District ("MSD") to show cause why the state

administrative hearing officer's decision in this case should not

be affirmed. Specifically, plaintiff was asked to point to a

genuine issue of material fact relative to the qualifying nature

of Kimberli's placement in a "home for children," or demonstrate

that the term "place" (and its variations) as used by the New

Hampshire legislature in N.H. Rev. Stat. Ann. Ch. ("RSA") 193 and

as applied to Kimberli, should be construed to mean "placed by the state."1 And, if the term "place" means "placed by the

state," MSD was asked to demonstrate that it is not now estopped

from arguing that Kimberli was not placed by the state, given

MSD's apparent failure to argue the point when it challenged its

liability as the "sending district" in 1992, in an separate

proceeding before the New Hampshire Department of Education.

Having considered plaintiff's memorandum, the opposing

memoranda, and after hearing oral argument, the court concludes

that the administrative hearing officer's decision is correct for

the reasons given in this court's March 26th Order, as briefly

supplemented below. Because there is no genuine dispute as to

material facts and, given the operative facts, the Manchester

School District ("MSD") remains the "sending district" with

regard to Kimberli's public education in the Pittsfield School

District, Defendant Kimberli M. is entitled to judgment as a

matter of law.

The factual and legal background relevant to this case is

fully set out in the court's March 26th Order and will not be

1 The phrase "placed by the state" is shorthand for the statute's literal language, "placed by the department of health and human services or a court of competent jurisdiction pursuant to RSA 169-B, RSA 169-C, RSA 169-D, or RSA 463." RSA 193:27.

2 repeated here, except as necessary to explain the court's

decision.

The parties agree that Kimberli is severely disabled, that

she lives and is "cared for in" a qualifying "home for children,"

within the meaning of RSA Ch. 193, and that she attends public

school in the Pittsfield School District, the district in which

the home for children is located. There is no reasonable dispute

that Kimberli physically resided in Manchester prior to being

placed in the home for children (though her legal residence, or

domicile, at the time is unclear). Certainly, MSD could have,

but did not challenge that physical residence in 1992, when it

first challenged its liability. Having failed to do so, it is

estopped from now denying that Kimberli "most recently resided

in" Manchester before being placed in the home for children. See

RSA 193:27, IV. It is also undisputed that Kimberli is (at least

for purposes of this decision) in the legal custody of a parent

who resides outside the state. Xd. So, if Kimberli was "placed"

in the home for children, then MSD remains the financially liable

"sending district."

Essentially, MSD asserts that the term "placed" as used in

the applicable statute means "placed by the state" with respect

3 to children who, like Kimberli, have been placed in a "home for

children." Because Kimberli was placed by her parents,2 and not

the state, MSD says it cannot qualify as the "sending district"

and cannot be held liable for the cost of Kimberli's public

education.

To support its position, MSD points to 1998 amendments to

RSA 193:27, IV, which inserted language expanding the definition

of "sending district" to include the school district in which a

child most recently resided other than "the home of a relative or

friend in which a child is placed by the department of health and

human services or a court of competent jurisdiction . . . ." MSD

says that qualifier — requiring that a child's placement in the

home of a relative or friend be arranged by the state as a

precondition to holding the child's previous school district of

residence financially liable for his or her public education —

2 The defendants believe that the circumstances of Kimberli's placement amounted to at least a de facto "placement by the state," but correctly note that that fact need not be determined if the phrase "placed in a home for children" includes placement by a parent. The court, for purposes of this decision, accepts MSD's claim that Kimberli was not "placed by the state." Of course, that factual dispute cannot be resolved against defendants in this context, but the assumption is not prejudicial since the fact is not critical to the court's analysis.

4 applies equally to children placed in a qualifying "home for

children." The court disagrees.

Neither the language of, nor the structure of the clauses

and sentences used in RSA 193:27, IV, as amended, supports MSD's

interpretation. The language inserted by the 1998 amendment is

set off by commas, a common device plainly intended to

communicate the intent to limit the "placed by the state"

qualifier to children placed in the home of a relative or friend.

The qualifier does not apply to children placed in "homes for

children," or in "health care facilities," or in "state

institutions." In limiting application of the "placed by the

state" qualifier to situations involving placements with friends

or relatives, the legislature undoubtedly recognized that such

placements are essentially involuntary and facially legitimate.

Therefore, the school district in which the relative or friend

lives should be reimbursed by the placed child's district, the

district ordinarily obligated to provide the child with a free

and appropriate public education. When children are placed with

relatives and friends voluntarily (i.e. without any state

intervention), however, there may be a risk of abuse, e.g.

parents placing their children with relatives in cities or towns

5 with better schools for the purpose of obtaining a public

education for them superior to that available in the parents'

hometown. To guard against such placements, the legislature has

generally precluded nonresident children from attending local

schools, absent at least a "recommendation" or "request" by the

department of health and human services that the child be placed

with a relative or friend. See RSA 193:12, V, and V-a ("Whenever

a parent . . .places a child with a relative at the

recommendation or request of the department . . . , that child

shall be permitted to attend the public schools of the school

district in which that relative resides . . . .") .

Thus, the 1998 amendments adding the qualifying language

regarding a child's placement with friends or relatives "by the

state," insured that the cost of such placement would be borne

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