Sadie Boyd, Madeline Klein & Town of Whitingham v. State
2022 VT 12
| Vt. | 2022Background
- Plaintiffs: student Sadie Boyd, property owner Madeleine Klein, and the Town of Whitingham sued the State alleging Vermont’s education funding and education property tax statutes violate the Education Clause, the Proportional Contribution Clause, and the Common Benefits Clause. The civil division granted summary judgment for the State; the Supreme Court affirmed.
- Twin Valley (the local district serving Whitingham) spent well above the Vermont average per equalized pupil (about $3,600 more than statewide; about $4,000 more than similarly sized districts) during 2016–2019, yet offered fewer in-person high-school courses and showed somewhat lower test/attendance metrics.
- Plaintiff Boyd testified she wanted more in-person course options and certain sports that Twin Valley did not offer; plaintiffs’ expert agreed that additional spending at current Vermont levels was unlikely to increase student achievement.
- Klein’s assessed property tax burden for education averaged roughly $4,000/year (after available income-sensitivity adjustments), which she contends is disproportionate and causes financial hardship.
- Relevant statutory framework: post-Brigham legislative funding reforms set statewide homestead and nonhomestead education tax rates via formulas, include an excess-spending penalty above a statutory threshold, and vest local voters with budget-setting authority; municipalities must collect taxes as directed by the Commissioner of Taxes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State’s funding system denies students a substantially equal educational opportunity (Education Clause/Common Benefits) | Boyd: Twin Valley’s limited in-person courses and weaker outcomes show unequal opportunity traceable to the funding/tax scheme | State: Twin Valley actually spends well above average; plaintiffs provided no causal link tying statutory funding/tax rules to the alleged deficiencies | Affirmed for State — plaintiffs failed to show the statutes caused the claimed deprivation; record lacks a non-speculative link between the funding scheme and Twin Valley’s alleged deficiencies |
| Whether the education property tax scheme forces Klein to contribute disproportionately (Proportional Contribution Clause) | Klein: Her education tax payments are disproportionately high compared to similarly situated taxpayers elsewhere | State: Tax burden depends on many variables; plaintiffs offered no comparative analysis showing unequal treatment of similarly situated taxpayers; classifications have conceivable legitimate bases | Affirmed for State — rational-basis review applies; plaintiffs failed to show arbitrary differential treatment or invalidate the excess-spending classification |
| Whether the Town can sue claiming it is compelled to collect an unconstitutional tax and is harmed by lost revenue | Town: Required to bill and remit education taxes and retains a small collection allowance, so it is compelled and harmed | State: Town’s derivative claims depend on plaintiffs proving the tax scheme unconstitutional; generally municipalities lack capacity to challenge State acts absent clear compulsion to violate the Constitution | Affirmed for State — Town’s derivative claims fail because plaintiffs did not prove the statutes unconstitutional; capacity/standing issues also support dismissal |
Key Cases Cited
- Brigham v. State, 692 A.2d 384 (established Vermont students’ right to substantially equal educational opportunity)
- Brigham v. State, 889 A.2d 715 (clarifying pleadings re: funding adequacy)
- In re Prop. of One Church St. City of Burlington, 565 A.2d 1349 (Proportional Contribution Clause requires reasonable relation and equitable application)
- Schievella v. Dep’t of Taxes, 765 A.2d 479 (tax classifications must have flexibility and rational basis)
- Town of Castleton v. Parento, 988 A.2d 158 (rational-basis test for tax classification challenges)
- Alexander v. Town of Barton, 565 A.2d 1294 (legislative classifications upheld if any conceivable legitimate purpose)
- Bernasconi v. City of Barre, 206 A.3d 720 (summary judgment: cannot rely on speculation)
- Mello v. Cohen, 724 A.2d 471 (pleadings sufficient at dismissal may be insufficient at summary judgment)
- Town of Andover v. State, 742 A.2d 756 (municipal capacity limits to challenge State legislation; narrow exception where compliance would force constitutional violation)
- Holton v. Dep’t of Emp. & Training, 878 A.2d 1051 (legitimate governmental interests can justify classifications affecting funding)