Zuni Public School District No. 89 v. Department of Education
Issues
Should the Supreme Court follow Chevron and defer to the Secretary of Education's formula to determine whether a school district should continue to receive federal funding, although the formula apparently conflicts with the statutory method?
The Federal Impact Aid Act provides federal funding to school districts located on Indian Reservations, military bases, or land with federal presence. Under the Act, the Secretary of Education can divert federal aid from the district back to the state if it determines that the state's school district operational funding is “equalized.” After determining that New Mexico's funding for the year 1999-2000 was equalized, the Secretary allowed the state to withhold federal subsidies from certain districts. The Zuni Public School District claims that the Secretary's formula for determining whether a school district receives federal subsidies conflicts with the plain meaning of the Act. In resolving this issue, the Supreme Court will clarify the scope of Chevron U.S.A., Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984), the seminal case governing agency interpretations of enabling legislation.
Questions as Framed for the Court by the Parties
Whether the Secretary has the authority to create and impose his formula over the one prescribed by Congress and through this process certify New Mexico's operational funding for fiscal year 1999–2000 as “equalized,” thereby diverting the Impact Aid subsidies to the State and whether this is one of the rare cases where this Court should exercise its supervisory jurisdiction to correct a plain error that affects all State school districts that educate federally connected children.
The Zuni Public School District (“Zuni”) is located almost entirely within Zuni and Navajo Reservation lands in New Mexico. Brief for Petitioner at 2. The Federal Impact Aid Act provides subsidies to Zuni as well as other school districts located on Indian Reservations, military bases, or land with other types of federal presence. 20 U.S.C. § 7709 et seq. (2000).
The authors would like to thank for Professor Jonathan Siegel for his insight into this case.