Town of Dartmouth v. Greater New Bedford Regional Vocational Technical High School District, 461 Mass. 366

Dartmouth and Fairhaven challenged the funding obligations imposed by the Education Reform Act on member municipalities in a regional vocational district.
The Regional Agreement (Feb. 25, 1972) set how operating costs were apportioned among New Bedford, Dartmouth, and Fairhaven based on pupil enrollment, with New Bedford, Dartmouth, and Fairhaven each responsible for their shares.
The Education Reform Act of 1993 created a foundation budget and wealth-based local contributions, superseding prior regional funding calculations for the members.
From 2003–2008, Dartmouth and Fairhaven paid substantially more under the Act’s formula than under the regional agreement, while New Bedford paid substantially less.
The Superior Court dismissed the complaint/cross claim as to standing and merits, and the Supreme Judicial Court affirmed the dismissal, holding the Act supersedes the regional agreement and that the municipalities lacked standing to challenge constitutionality.
The Court concluded the Education Reform Act’s comprehensive statewide funding framework preempts inconsistent local funding provisions and that Dartmouth and Fairhaven cannot challenge the Act’s constitutionality.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do the Education Reform Act funding provisions preempt the regional agreement?	Dartmouth argues the Act does not repeal the regional agreement.	Defendants contend the Act supersedes regional funding terms.	Act supersedes regional agreement.
Do Dartmouth and Fairhaven have standing to challenge the Act's constitutionality?	Dartmouth and Fairhaven claim standing as parties affected by the Act.	State cannot be challenged by its own political subdivisions lacking personhood to sue the state.	No standing.
Can the Special Act be construed harmoniously with the Education Reform Act to avoid implied repeal?	Special Act and Act can coexist with the Act defining minimum funding for all districts.	The Act creates a statewide framework that overrides prior local arrangements.	Demonstrably implied repeal avoided; conflict resolved by preemption of local terms by Act.
Does the Home Rule Amendment permit municipalities to challenge the Act?	Home Rule amendment preserves local self-government against state funding changes.	Comprehensive state-wide reform falls within state power and isn’t precluded by Home Rule.	No standing to challenge under Home Rule Amendment.

Boston Teachers Union, Local 66 v. Boston, 382 Mass. 553 (1981) (preemption by state law where comprehensive statutes prevail)
Emerson College v. Boston, 393 Mass. 303 (1984) (strong implication against implied repeal by later general law)
Doherty v. Commissioner of Admin., 349 Mass. 687 (1965) (conflict between earlier special statute and later general statute; implied repeal only when irreconcilable)
Holden v. Wachusett Regional Sch. Dist. Comm., 445 Mass. 656 (2005) (minimum local contributions supersede regional agreement assessments)
Spence v. Boston Edison Co., 390 Mass. 604 (1983) (governmental entities generally lack standing to challenge acts of their creator)
Brookline v. The Governor, 407 Mass. 377 (1990) (standing discussion; dicta not controlling for municipalities)
Massachusetts Bay Transp. Auth. v. Auditor of the Commonwealth, 430 Mass. 783 (2000) (agency lack of standing to challenge state statute)
Clean Harbors of Braintree, Inc. v. Board of Health of Braintree, 415 Mass. 876 (1993) (agency standing limitations in constitutional challenges)