Court clarifies education funding rules in Northern Mariana Islands

The Supreme Court of the Commonwealth of the Northern Mariana Islands (CNMI) issued a significant ruling on January 14, 2020, regarding the funding of the Public School System (PSS). This decision affects how education is financed in the CNMI, clarifying the definitions and rules surrounding the allocation of funds to schools. The ruling is crucial for ensuring that the PSS receives its constitutionally guaranteed share of the budget.

The case, titled In the Matter of a Petition for Certified Question (docket number 2018-SCC-0021-CQU), involved Governor Ralph DLG. Torres and Marylou S. Ada, Chairperson of the Board of Education. They submitted three certified questions to the court, seeking clarification on the provisions governing education financing as outlined in Article XV, Section 1(e) of the NMI Constitution. This section guarantees PSS an annual budget of at least twenty-five percent of the general revenues of the Commonwealth.

The questions posed by the petitioners focused on the sources of income that should be included in determining PSS’s guaranteed budget, whether the legislature could suspend earmarks in appropriations bills, and the entitlement of PSS to a share of supplemental budgets during a fiscal year. The court's ruling addressed these questions, providing clarity on the financial framework for education in the CNMI.

Background

The parties involved in this case are Governor Ralph DLG. Torres and Marylou S. Ada, the Chairperson of the Board of Education. The dispute arises from the need to interpret the constitutional provisions related to education financing in the CNMI. The NMI Constitution has always included provisions on education, but specific aspects of education financing were not adopted until ten years after the Constitution's original ratification.

The NMI Constitution was ratified in 1978, and it included a provision for education but did not initially specify how it would be financed. It wasn't until 1985 that an amendment was made, establishing that the public elementary and secondary education system would receive an annual budget of not less than fifteen percent of the general revenues of the Commonwealth. This percentage was later increased to twenty-five percent in 2014, reflecting the growing importance of education funding in the CNMI.

The petitioners sought the court's guidance to define the contours of Article XV, Section 1(e) of the NMI Constitution, particularly in light of the historical context of education financing and the legislative practices that have developed over the years. The court's decision aimed to clarify the responsibilities of the Governor and the Board of Education in relation to the funding of PSS.

The Ruling

The Supreme Court, led by Chief Justice Alexandro C. Castro, ruled on the three certified questions presented by the petitioners. The court concluded that PSS is constitutionally entitled to general revenues, not special revenues. It determined that the legislature may suspend an earmark in an appropriations bill, which would transform those revenues into general revenues that PSS is entitled to a percentage of. Furthermore, the court ruled that PSS is entitled to a portion of supplemental budgets when there is a revenue surplus, but in the case of a revenue shortfall, the legislature may proportionately reduce PSS’s budget as long as its twenty-five percent share is maintained.

In the opinion, the court stated, "PSS is constitutionally entitled to general revenues, not special revenues," and emphasized the importance of maintaining the constitutionally mandated funding for education. The court highlighted that the definitions of general and special revenues must be clearly understood to ensure that PSS receives its guaranteed funding.

The ruling emphasized the need for a balance between the ordinary understanding of revenue terms and the intent of the drafters of the NMI Constitution. The court's interpretation aims to protect the financial stability of PSS and ensure that the educational needs of the community are met.

Impact

This ruling has significant implications for the future of education funding in the CNMI. By clarifying the definitions of general and special revenues, the court has established a framework that will guide how funds are allocated to PSS. This decision ensures that PSS will receive its constitutionally guaranteed share of the budget, regardless of fluctuations in general revenues.

The ruling also sets a precedent for how future appropriations and supplemental budgets will be handled in relation to education funding. It underscores the importance of adhering to constitutional mandates when it comes to financing public education, thereby reinforcing the commitment to providing quality education for all students in the CNMI.

What's Next

Details were not available in the court filing regarding whether this ruling can be appealed. However, it is clear that the decision will shape future discussions and policies related to education financing in the CNMI. The court's interpretation of the constitutional provisions will likely influence legislative actions and appropriations for years to come.