Kingston Hill Academy v. Chariho Regional School District
21 A.3d 264
| R.I. | 2011Background
- Chariho filed a writ of certiorari to review a board decision on charter-school tuition payments and an asserted affirmative defense.
- The board reversed the commissioner’s interpretation of § 16-77.1-2(d) and held Chariho must base local payments on the number of district students enrolled in the charter schools by quarter, starting 2010.
- Chariho argued the statute should base payments on actual enrollment, not a reference-year method, to avoid absurd results.
- The commissioner had severed Chariho’s unclean-hands defense as a counterclaim; the board affirmed severance.
- Chariho challenged the severance as due-process error and the statutory construction as rewriting the statute.
- Rhode Island Supreme Court granted the petition and ultimately affirmed the board’s decision while quashing the writ.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of severance of unclean hands defense | Chariho contends severance violated due process. | Board treated defense as tangential to claims and properly severed. | Severance affirmed; not a true affirmative defense and properly separated. |
| Statutory construction of § 16-77.1-2(d)-(e) for local payments | Chariho argues payments based on actual enrollment, not reference year. | Board correctly construed that subsection (e) uses timing, not calculation, of payments. | Board's interpretation that local payments are quarterly based on actual enrollment is affirmed. |
| Notice/hearing on dollar amount of tuition owed | Chariho sought a hearing to determine exact dollar amount. | Issue not in petition for certiorari; no remand for amount calculation. | Denied; issue outside petition scope. |
Key Cases Cited
- Asadoorian v. Warwick School Committee, 691 A.2d 573 (R.I.1997) (deferential standard for agency statutory construction)
- West v. McDonald, 18 A.3d 526 (R.I.2011) (deference to agency construction when not clearly erroneous)
- Downey v. Carcieri, 996 A.2d 1144 (R.I.2010) (statutory interpretation framework)
- Harvard Pilgrim Health Care of New England, Inc. v. Rossi, 847 A.2d 286 (R.I.2004) (statutory interpretation and legislative intent)
- Such v. State, 950 A.2d 1150 (R.I.2008) (policy-oriented interpretation and public purpose)
- Pawtucket Transfer Operations, LLC v. City of Pawtucket, 944 A.2d 855 (R.I.2008) (deference to agency interpretation when reasonable)
- Ryan v. City of Providence, 11 A.3d 68 (R.I.2011) (treat statute as a whole to determine intent)
- Such v. State, 950 A.2d 1150 (R.I.2008) (consider statutes as a whole for legislative intent)
- Town of North Kingstown v. Albert, 767 A.2d 659 (R.I.2001) (avoid absurd results in statutory construction)