Town of Warren v. Bristol Warren Regional School District and Town of Bristol by and through its Town Council and its Town Treasurer, Julie Goucher, As Interested Party.

159 A.3d 1029, 2017 WL 2057130, 2017 R.I. LEXIS 56
CourtSupreme Court of Rhode Island
DecidedMay 12, 2017
Docket15-363, 15-364
StatusPublished
Cited by16 cases

This text of 159 A.3d 1029 (Town of Warren v. Bristol Warren Regional School District and Town of Bristol by and through its Town Council and its Town Treasurer, Julie Goucher, As Interested Party.) 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
Town of Warren v. Bristol Warren Regional School District and Town of Bristol by and through its Town Council and its Town Treasurer, Julie Goucher, As Interested Party., 159 A.3d 1029, 2017 WL 2057130, 2017 R.I. LEXIS 56 (R.I. 2017).

Opinion

OPINION

Justice Flaherty,

for the Court.

These consolidated appeals arise from a judgment of the Superior Court regarding the statutory interpretation of the manner in which state education aid funds that are received by the Bristol Warren Regional School District (BWRSD or district) should be calculated and apportioned to its constituent towns, Bristol and Warren. The defendants, the BWRSD, the Bristol Warren Regional School Committee (BWRSC or committee), and the Town of Bristol, appeal from a Superior Court judgment granting Warren’s petition and complaint for declaratory judgment. 1 The defendants argue that the trial justice misconstrued the Rhode Island Board of Education Act, G.L. 1956 chapter 7 of title 16 (Education Act) and the Rhode Island Education Equity and Property Tax Relief Act, G.L. 1956 chapter 7.2 of title 16 (Funding Formula Act). The defendants further maintain that the trial justice failed to accord proper deference to the Rhode Island Department of Education’s (RIDE) interpretation of those statutes. In a separate argument, Bristol posits that the Superior Court did not have jurisdiction over this declaratory-judgment action because Warren failed to join all interested parties and further that Warren’s claims are barred by the doctrine of res judicata. After careful consideration of the record, and for the reasons set forth in this opinion, we affirm the judgment of the Superi- or Court.

I

Facts and Travel

The BWRSD and the Enabling Legislation

The contiguous towns of Bristol and Warren form the BWRSD, which was established pursuant to chapter 330 of the 1991 Public Laws of Rhode Island (enabling legislation). The BWRSC, consisting of nine members, was created to govern the BWRSD in accordance with the enabling legislation. The Joint Finance Committee (JFC) was formed under P.L. 1991, ch. 330, sec. 3, § X(I)(3) of the enabling legislation; it consists of nine members appointed by the town councils of Bristol and Warren. At the time of the dispute, the JFC comprised six representatives from Bristol and three from Warren. 2

*1032 The enabling legislation lays out the approval process for the district’s annual budget. In that regard, it provides that the superintendent of the district is to prepare and present a preliminary annual budget to the committee containing estimates of the funds needed to operate the district for the ensuing fiscal year. The committee then submits its proposed budget to the JFC for approval. Upon approval of the budget, each town is required to appropriate funds for the district, which are “apportioned between the cities on a per public pupil calculation using enrollment as of the prior October 1,” pursuant to the enabling legislation. 3

The parties have stipulated 4 that, since the formation of the BWRSD, its treasurer would reduce the annual budget, as approved by the JFC, by the total amount of state aid and any other miscellaneous revenue sources, and then would apportion the remaining balance of the budget by the student population, on a per-capita basis from each municipality.

The Prior Litigation

In 2012, the BWRSD and the BWRSC filed suit against Warren, seeking a declaratory judgment and a writ of mandamus, demanding that Warren appropriate its full share of the 2012-2013 school budget for the BWRSD, as was determined by the JFC. See Bristol Warren Regional School District v. Town of Warren, No. PC12-4653, 2014 WL 1396941 (Apr. 4, 2014) (the prior litigation). The budget for that fiscal year required that Warren pay the sum of $12,164,919 to the district. Id. at *2. However, Warren balked; at its financial town meeting, the town voted to appropriate only $11,748,919 of the budgeted amount. Id. In April 2014, the Superior Court determined that Warren was not authorized to reject a budget that had been approved by the JFC because the enabling legislation cloaked the JFC with final budgetary authority. Id. at *6. Therefore, the court ordered Warren to appropriate the additional funds to the BWRSD. Id. That judgment was not appealed.

The Current Dispute

In early December 2013, while the prior litigation remained pending, the state representative for Warren contacted RIDE about the state calculations for the education aid funding formula. In particular, he questioned why Bristol and Warren were assessed the same local share per pupil even though Warren students, because of a higher rate of state aid, were generating a greater per-pupil share of the state revenues. In response to his inquiry, RIDE provided a spreadsheet that compared the formula aid by. region and by member town for the BWRSD. According to Warren, those calculations “confirmed Warren’s claim that it would in fact receive more aid if the calculations were made with reference to the comparative rates of students receiving free or reduced price lunch, rather than with reference to a blended figure.”

In March 2014, Warren’s finance director received an email from the district informing him of the projected 2014-2015 school budget. That same day, the finance director submitted a memorandum to the town manager, indicating that the proper allocation of state education aid should be *1033 on a weighted per-pupil basis in accordance with the basis of need of the municipalities. Attached to the memorandum was RIDE’s funding formula analysis for the 2015 fiscal year showing the figures for Bristol and Warren, both separately and as a regional district. The memorandum was presented to the JFC shortly thereafter. The JFC, however, did not adopt the recommendations set forth in the memorandum.

Later that month, Warren filed a petition for writ of mandamus, injunctive relief, and a complaint for declaratory judgment against the BWRSD, the BWRSC, and the Town of Bristol. In its filing, Warren claimed that the enabling legislation and the Funding Formula Act required that state aid be allocated not on a per-capita per-pupil basis, but on a weighted per-pupil basis, taking into account the number of students with free or reduced-price lunch in each town, the median income of each town, and the total assessed property values of each town.

The Lower Court Proceedings

During a hearing on May 12, 2014, RIDE’s senior finance officer testified that RIDE made use of specific data components to determine state education aid for individual districts. Those data components include the state share ratio, which consists of, among other factors, property values, free and reduced-price lunch data for students, and adjusted equalized weighted assessed valuations (EWAV). The senior finance officer affirmed that, under the funding formula, a poorer community typically is allocated more money from the state for education aid than a more affluent community.

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Cite This Page — Counsel Stack

Bluebook (online)
159 A.3d 1029, 2017 WL 2057130, 2017 R.I. LEXIS 56, Counsel Stack Legal Research, https://law.counselstack.com/opinion/town-of-warren-v-bristol-warren-regional-school-district-and-town-of-ri-2017.