City of Woonsocket v. RISE Prep Mayoral Academy, 251 A.3d 495

Background

RISE Prep Mayoral Academy (a Rhode Island nonprofit mayoral charter school) entered a purchase agreement to buy 30 Cumberland Street in Woonsocket and requested a zoning certificate before closing.
The Woonsocket zoning official issued a January 29, 2018 certificate stating the property is in a C-2 (Major Commercial) district and concluding that, under R.I. law, a charter school is a public school and thus a municipal use allowed in C-2.
RISE obtained state approval for the construction project and began planning to relocate; the City Council adopted a resolution asserting that RISE’s operation at the site would violate the zoning ordinance and present safety issues.
The City sued for a declaratory judgment and injunctive relief, arguing RISE’s operation is a prohibited “nonprofit educational institution serving young children” in a C-2 zone.
The Superior Court found the zoning ordinance ambiguous, concluded state law (Charter Public School Act) deems charter schools public schools, credited the zoning official’s interpretation, and held RISE’s operation is a municipal use permitted in C-2.
The Supreme Court affirmed, holding that under §16-77-3.1(b) RISE is a public school and its operation qualifies as a municipal use allowed in the C-2 district.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RISE’s operation is a prohibited “nonprofit educational institution serving young children” in C-2 or a permitted municipal (public school) use	RISE fits the specific prohibited category in §4.5.6, so that specific restriction controls over the general municipal-use allowance	RISE is a charter public school under state law; as a public school it is a municipal use permitted in C-2	Held for defendants: state statute deems charter schools public schools, so RISE is a municipal use permitted in C-2
Whether the trial court should have applied the specific-over-general canon to the ordinance	The specific prohibition must prevail over the general municipal-use provision	The ordinance is silent as to charter public schools and state law controls, making the canon inapplicable	Held: the specific-general maxim does not resolve the conflict because RISE is both a nonprofit educational institution and, by statute, a public school; §16-77-3.1(b) governs
Whether the trial justice erred by according weight to the zoning official’s interpretation	Deference to the zoning official was improper; court should independently interpret the ordinance	Municipal officials’ interpretations merit some deference; trial justice reasonably weighed the official’s credible testimony	Held: trial justice properly assigned weight to the zoning official’s credible testimony while independently construing statute and ordinance
Whether the trial justice misapplied the law or overlooked evidence/credibility issues	City contends trial justice misconstrued ordinance, ignored comprehensive-plan provisions, and misapplied deference	Trial justice made permissible credibility findings, considered ordinance, plan, statute, and testimony, and reached supported conclusions	Held: factual findings and legal conclusions are supported; no reversible error

Key Cases Cited

Town of West Greenwich v. A. Cardi Realty Associates, 786 A.2d 354 (R.I. 2001) (standard for reversing a nonjury judgment)
Process Engineers & Constructors, Inc. v. DiGregorio, Inc., 93 A.3d 1047 (R.I. 2014) (deference to trial-justice factual findings)
Prew v. Employee Retirement System of City of Providence, 139 A.3d 556 (R.I. 2016) (statutes and ordinances are interpreted the same way)
Sauro v. Lombardi, 178 A.3d 297 (R.I. 2018) (clear statutory language gets its plain meaning)
Whitehouse v. Moran, 808 A.2d 626 (R.I. 2002) (specific statutory provision generally prevails over a general one)
Nunes v. Town of Bristol, 232 A.2d 775 (R.I. 1967) (courts may consider extrinsic matters to ascertain legislative intent)
City of Pawtucket v. Sundlun, 662 A.2d 40 (R.I. 1995) (General Assembly has plenary authority over public education)
New England Expedition-Providence, LLC v. City of Providence, 773 A.2d 259 (R.I. 2001) (municipal officials’ enforcement interpretations merit some deference)
Town of Warren v. Bristol Warren Regional School District, 159 A.3d 1029 (R.I. 2017) (distinguishing different levels of deference to administrative constructions)
Hilley v. Lawrence, 972 A.2d 643 (R.I. 2009) (trial-justice credibility findings are accorded deference)