## Facts

- Several New Hampshire school districts, schoolchildren, and taxpayers challenged the State’s public-education financing and oversight system as violating the State Constitution’s education mandate.
- Earlier decisions in the same litigation recognized a fundamental right to a State-funded constitutionally adequate public education and assigned the Legislature responsibility to define, cost, and fund adequacy through equal-rate, proportional taxation.
- The Supreme Court retained continuing jurisdiction over compliance.
- In 2001, plaintiffs returned seeking a ruling that the State had failed to create adequate standards of accountability to ensure the constitutionally required minimum education.
- The case required evaluating whether the State’s duty to provide an adequate education includes enforceable accountability measures and whether the then-current statutes and regulations met that duty.

## Issues

1. Whether the State’s obligation to provide a constitutionally adequate public education requires standards of accountability in the educational system.
2. Whether existing statutes, regulations, and rules satisfied any such accountability obligation.

## Decision

- The court held that accountability is an essential component of the State’s constitutional duty to provide a constitutionally adequate public education.
- The court held that the existing statutory and regulatory framework contained deficiencies inconsistent with that duty.
- The court declined to design a detailed accountability regime itself, emphasizing legislative primacy in defining and implementing adequacy.
- The court retained continuing jurisdiction to ensure constitutional compliance.

## Legal Principles

- The State Constitution imposes an enforceable duty on the State to provide a constitutionally adequate public education and to support public schools.
- The right to a constitutionally adequate public education is a fundamental right; failure to provide it triggers heightened judicial review.
- The Legislature bears primary responsibility to define educational adequacy, determine its cost, and fund it through taxes that are equal in rate and proportional in valuation.
- A constitutional adequacy mandate requires workable mechanisms to define, measure, and enforce compliance; general aspirations or vague standards are insufficient.

## Conclusion

The court ruled that the State’s constitutional obligation to provide a constitutionally adequate education necessarily includes enforceable accountability standards, and it declared the then-existing statutory scheme constitutionally insufficient in that respect while leaving corrective design to the political branches under ongoing judicial oversight.


Claremont Sch. Dist. v. Governor, 794 A.2d 744 (N.H. 2002)