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
| R.I. | 2017Background
- Bristol and Warren formed the Bristol Warren Regional School District (BWRSD) by 1991 enabling legislation; the Joint Finance Committee (JFC) approves the district budget and member towns appropriate their shares based on a per‑pupil apportionment.
- RIDE calculates state foundation aid using a funding formula that depends on community-level factors (EWAV, median income, concentration of high‑need students); RIDE historically computed aid at the regional level for BWRSD and disbursed a lump sum to the district.
- Warren discovered RIDE’s regional calculation produced a lower per‑pupil state aid attribution to Warren than if aid had been calculated separately for each town; Warren alleged this effectively shifted Warren’s state aid to Bristol.
- Warren sued the BWRSD, BWRSC, Bristol and later RIDE seeking declaratory relief and mandamus, arguing state law requires RIDE to calculate and disburse funding separately for each member town and allocate credits accordingly.
- The Superior Court held the Funding Formula requires city/town‑specific EWAV allocations and ordered RIDE to calculate and disburse funds separately to Bristol and Warren; defendants appealed.
Issues
| Issue | Plaintiff's Argument (Warren) | Defendant's Argument (BWRSD / Bristol / BWRSC / RIDE) | Held |
|---|---|---|---|
| Whether res judicata bars Warren’s claims | Prior judgment addressed different statutory issue; current suit raises distinct statutory interpretation | Prior litigation decided related budget/payment disputes and thus bars relitigation | Not barred. No identity of issues; res judicata did not apply. |
| Whether all necessary parties were joined under § 9‑30‑11 | No other parties have an actual, present, adverse interest; joinder of other districts speculative | Failure to join all affected parties (other districts/municipalities) deprives court of jurisdiction | Joinder not required here; trial court did not abuse discretion in exercising jurisdiction. |
| Degree of deference due to RIDE’s interpretation | RIDE’s informal guidance is not a legislative rule and is not entitled to Chevron‑level deference | RIDE administers the statutes and its reading is entitled to substantial deference | RIDE’s memorandum was interpretive (not rule‑making); limited persuasive weight only. Court applied its own de novo statutory interpretation. |
| Proper statutory method to calculate and allocate state funding to regional districts | Funding Formula requires separate town‑level EWAV and other factors; RIDE must calculate and disburse funds separately to each member town | Statutory definition of “community” includes regional districts, so aid may be calculated and disbursed at the regional level | Held for Warren: statutes (read as a whole) require EWAV and related adjustments to be attributed to each city and town; RIDE must calculate and disburse funds separately to member towns. |
Key Cases Cited
- Chevron U.S.A., Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984) (framework for judicial deference to agency statutory interpretations)
- Unistrut Corp. v. State Department of Labor & Training, 922 A.2d 93 (R.I. 2007) (agency interpretations entitled to deference unless clearly erroneous)
- Bucci v. Lehman Brothers Bank, FSB, 68 A.3d 1069 (R.I. 2013) (standards for appellate review of declaratory‑judgment decisions)
- Ritter v. Mantissa Investment Corp., 864 A.2d 601 (R.I. 2005) (res judicata transactional test and identity‑of‑issues analysis)