Zuni Public School District No. 89 v. Department of Education
Headline: Upheld pupil-weighted spending test: Court allows Education Department to use student-weighted percentiles, letting states offset federal impact aid by reducing state aid when funding is certified equalized.
Holding: The Court held that the Secretary may identify districts to 'disregard' by using student‑population weighted percentiles of per‑pupil spending, making the Department’s pupil‑weighted calculation lawful.
- Allows states to offset federal impact aid when certified equalized under pupil weighting.
- Validates the Department’s long‑standing pupil‑weighted disparity test.
- Changes which districts are excluded from disparity calculations and funding adjustments.
Summary
Background
Two New Mexico public school districts (Zuni Public School District and Gallup‑McKinley) challenged the Department of Education’s method for deciding when a State’s aid program “equalizes expenditures.” The Impact Aid law bars States from offsetting federal impact payments by reducing state aid unless the Secretary certifies the State equalizes per‑pupil spending. Department regulations rank districts by per‑pupil spending, then identify 5th and 95th percentile cutoffs by counting pupils, exclude those outliers, and compare the remaining highest and lowest per‑pupil figures. In New Mexico officials ranked 89 districts, excluded districts representing about 10% of pupils at each end, and found the remaining disparity below 25%. Zuni conceded the regulations were followed but argued percentiles should be based on the number of districts. An agency judge, the Secretary, and the en banc Tenth Circuit rejected Zuni’s claim.
Reasoning
The Court addressed whether the statute permits the Secretary to identify districts to “disregard” by looking to district pupil counts as well as per‑pupil expenditures. It found the question technical and noted the Secretary had long used the pupil‑weighted method. The Court concluded the statutory phrase about the 95th and 5th percentiles does not unambiguously prescribe a single calculation method, that the pupil‑weighted approach fits the purpose of excluding statistical outliers, and that deference to a reasonable agency interpretation is appropriate.
Real world impact
The ruling lets the Department’s long‑standing pupil‑weighted test remain in force. States may be certified as “equalized” using that method and may reduce state aid to offset federal impact payments when the Secretary so certifies. The decision keeps the Department’s nationwide practice and affects which districts may lose state funding.
Dissents or concurrances
Justice Scalia dissented, arguing the statute’s plain text forbids the pupil‑weighted method; Chief Justice Roberts and Justice Thomas joined that dissent and Justice Souter joined Part I. Justices Stevens and Kennedy filed separate opinions emphasizing legislative history and the proper deference framework.
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