Zuni Public School Dist. No. 89 v. Department of Education (2006)
- Docket
- 05-1508
- Decided
- 2006-01-01
Summary
Question: Was the Secretary of Education's regulatory formula for determining whether a state's education funding is equalized among its school districts consistent with 20 U.S.C. Section 7709, the Federal Impact Aid Program? Conclusion: Yes. The Court voted 5-4 in favor of the Department of Education, affirming the lower court. In his majority opinion, Justice Stephen Breyer agreed with the Secretary of Education's argument that 20 U.S.C. 7709 was ambiguous on the specific formula to be used. Since administrative agencies have wide latitude to interpret their governing statutes, the Court gave deference to the Secretary's formula for calculating the 5th and 95th percentiles for the purpose of determining expenditure equalization. The majority concluded that "[...] the history of the statute strongly supports the Secretary." No member of Congress had expressed an opinion on the formula to be used, so the Department would have been free to calculate the percentiles using either formula. In response to Zuni's statutory-language based argument, the Court ruled that the statute's phrasing could encompass the Secretary's method of calculating excluded districts based on per-pupil expenditure percentiles of the total student population. The four dissenting Justices argued that the statute required the Secretary to calculate the percentiles based on a comparison of the per-pupil expenditures of the districts.