Newport School Committee v. Rhode Island Department of Education; Cumberland School Committee v. Rhode Island Council on Elementary and Secondary Education

CourtSupreme Court of Rhode Island
DecidedFebruary 3, 2026
Docket2021-0037-M.P. and 2021-0038-M.P.
StatusPublished

This text of Newport School Committee v. Rhode Island Department of Education; Cumberland School Committee v. Rhode Island Council on Elementary and Secondary Education (Newport School Committee v. Rhode Island Department of Education; Cumberland School Committee v. Rhode Island Council on Elementary and Secondary Education) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Newport School Committee v. Rhode Island Department of Education; Cumberland School Committee v. Rhode Island Council on Elementary and Secondary Education, (R.I. 2026).

Opinion

Supreme Court

(Dissent begins on Page 12)

Newport School Committee : No. 2021-37-M.P. (PC 19-4024) v. :

Rhode Island Department of : Education et al.

Cumberland School Committee : No. 2021-38-M.P. (PC 20-31) v. :

Rhode Island Council on Elementary : and Secondary Education et al.

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Newport School Committee : No. 2021-37-M.P. (PC 19-4024) v. :

Cumberland School Committee : No. 2021-38-M.P. (PC 20-31) v. :

Rhode Island Council on Elementary : and Secondary Education et al.

Present: Suttell, C.J., Goldberg, Robinson, and Lynch Prata, JJ.

OPINION

Justice Lynch Prata, for the Court. These consolidated cases came before

the Supreme Court pursuant to a writ of certiorari issued upon petitions by the

defendant, the Department of Children, Youth, and Families (DCYF), seeking

review of a Superior Court judgment in favor of the plaintiffs, Newport School

Committee (Newport) and Cumberland School Committee (Cumberland)

(collectively, plaintiffs). The matter was previously before this Court on the full

argument calendar, resulting in an opinion resolving the first of two issues that were

presented. See Newport School Committee v. Rhode Island Department of

Education, 316 A.3d 1159, 1164 (R.I. 2024). These cases arise out of the plaintiffs’

-1- decision not to reimburse DCYF at the “per-pupil special-education” rate for the cost

of educating children who were placed in residential treatment programs by DCYF,

but who were not receiving special education services.

In our opinion dated June 28, 2024, we identified that there were two issues

presented by DCYF’s petition: (1) “whether the trial justice erred in finding that the

statute did not require the municipalities to pay the per-pupil special-education rate

regardless of whether the children received special-education services” and (2)

“whether the trial justice erred in finding that the statute obligated the municipalities

to pay the per-pupil general-education rate even though the reference to general

education was removed from the statute.” Newport School Committee, 316 A.3d at

1164. In resolving the first issue, we held that “[p]ursuant to the clear and

unambiguous language of [G.L. 1956] §§ 16-64-1.1 and 16-64-1.2, municipalities

are not required to reimburse DCYF at the per-pupil special-education rate when

there were no special education services rendered and thus, no special education

costs incurred.” Id. We then “direct[ed] the parties to file supplemental briefs” on

the remaining issue now before us: “[W]hether the trial justice erred in finding that

the statute obligated the municipalities to pay the per-pupil general-education rate

even though the reference to general education was removed from the statute.” Id.

For the reasons set forth herein, we quash the decision of the Superior Court.

-2- Facts and Travel

Although the facts of this case were laid out in this Court’s first opinion in

this matter, we reiterate those necessary for context of the remaining issue. In 2018,

the Family Court placed two children, A. Doe and M. Doe, in the temporary custody

of DCYF. 1 The Family Court designated Newport and Cumberland, respectively,

as the residences of the children’s custodial parents for the purpose of determining

the municipalities’ financial responsibility for the children’s education. DCYF

subsequently placed A. Doe at Harmony Hill School and M. Doe at Meadowridge

Academy. Neither student received special education services in their respective

placements.

These consolidated cases began when DCYF filed two “Request[s] for an

Order for Residency Determination and Designation of Party Responsible for the

Education of a Youth Residing in a Residential Facility” with the Commissioner of

Elementary and Secondary Education (the commissioner), arguing that the

municipalities were required to pay the per-pupil special-education rate pursuant to

the unambiguous language of §§ 16-64-1.1 and 16-64-1.2. The commissioner

agreed with DCYF in each case, issuing two decisions that ordered Newport and

Cumberland to reimburse DCYF for the cost of educational services provided to the

1 A. Doe and M. Doe were minors during the Family Court proceedings. We use pseudonyms to respect their privacy.

-3- children at the special-education rate. After the Council on Elementary and

Secondary Education denied Newport’s and Cumberland’s independent appeals of

the commissioner’s decisions, the municipalities appealed to the Superior Court

pursuant to the Administrative Procedures Act, G.L. 1956 chapter 35 of title 42.

A justice of the Superior Court consolidated the two cases and issued a written

decision, determining that the clear and unambiguous language of § 16-64-1.1(c)

required the designated city or town to pay “its share of the cost of educational

services to DCYF” rather than the higher, per-pupil special-education rate.

(Emphasis omitted) (quoting § 16-64-1.1(c)). The trial justice determined that

§ 16-64-1.1(c) was devoid of language that obligated the municipalities to pay “more

than its share at a rate inconsistent with the educational services provided to the

child.” She further rejected Cumberland’s argument that the statute did not require

it to pay any of the cost of education, reasoning that “there is no support in either

statute for [that] position * * *.”

The trial justice determined that, even if the statute were ambiguous, the

outcome would not differ because requiring the municipalities to pay almost two and

a half times the cost of the children’s education would be absurd. She therefore

granted the appeals, concluding that Newport and Cumberland were responsible for

the per-pupil general-education costs and ordered each municipality to reimburse

DCYF in the amounts due. Judgment was entered in favor of Newport and

-4- Cumberland, and DCYF filed, and we granted, a petition for writ of certiorari in each

case.

This Court issued an opinion resolving the first of two issues. See Newport

School Committee, 316 A.3d at 1164. Quoting the relevant statutory language, this

Court stated:

“Section 16-64-1.1(c) provides that the ‘city or town determined to be responsible to DCYF for a per-pupil special-education cost pursuant to § 16-64-1.2 shall pay its share of the cost of educational services to DCYF * * *.’ Section 16-64-1.1(c) (emphasis added). Section 16-64-1.2 provides that, in circumstances where the parents’ residency is not determined by the Family Court, the department of elementary and secondary education ‘shall designate the city or town to be responsible for the per-pupil special education cost of education to be paid to DCYF * * *.’ (Emphasis added.)” Id. at 1163-64.

We then concluded that “[t]he term ‘cost’ refers to ‘the amount or equivalent paid

or given or charged * * * for anything bought or taken in barter or for service

rendered.’” Id. at 1164 (quoting Webster’s Third New International Dictionary 515

(1971)).

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Newport School Committee v. Rhode Island Department of Education; Cumberland School Committee v. Rhode Island Council on Elementary and Secondary Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/newport-school-committee-v-rhode-island-department-of-education-ri-2026.