In a 32-page opinion, written by Chief Justice Paul A. Suttell, the Supreme Court of Rhode Island affirmed the judgment of the lower court (Superior Court Associate Justice Jeffrey A. Lanphear Judith C. Savage) in favor of the defendants, the members of the Cranston City Council, the Mayor, and the Director of Finance and against the plaintiffs – the School Committee of the City of Cranston and the Superintendent of Schools – who had brought this “Caruolo action” seeking additional city funds for city schools for the fiscal year (FY) 2007-2008.
The plaintiffs contended that the trial justice erred in concluding that the school committee did not meet the statutory prerequisites for filing a Caruolo action under R.I.G.L. 1956 § 16-2-21.4, as well as alleging a number of other errors.
The Court concluded that, in light of the language of the Caruolo Act itself, as well as the other pertinent provisions of G.L. 1956 chapter 2 of title 6, it was clearly the General Assembly’s intent to encourage expeditious action in instances of potential school deficit spending. The Court therefore affirmed the trial justice’s application of the doctrine of laches in the instant case. The Court further held that the trial justice did not abuse her discretion in discussing the plaintiffs’ failure to conform to other statutory requirements prior to bringing the Caruolo action.