Two residents of the City of Concord sued the State Department of Education and the local school district after the state department approved the construction of two new schools on lots smaller than required by existing administrative rules. The residents argued that, as taxpayers, they had "legal standing" to assert the claims purely because they were taxpayers in the affected municipality. They did not argue that any of their personal rights or property were affected by the decision.
Past cases from the Supreme Court had indicated that merely being a taxpayer was enough to allow a person to bring an action forward. But more recent cases had retreated from this view and only allowed persons who alleged some injury to their personal property or rights to proceed in court. In this opinion, the Court overruled the older cases and held that "…taxpayer status, without an injury or an impairment of rights, is not sufficient to confer standing to bring a declaratory judgment action under RSA 491:22."
While this may seem to be a technical rule that is only of interest to lawyers, it is actually important to everyone. This holding means that the group of persons who will potentially be allowed to file a challenge to any new law, administrative rule, ordinance or regulation is significantly reduced. Thus, the likelihood of court challenges to new enactments of all types is much smaller than it otherwise might have been. The door to the courthouse is not closed, but the opening is much narrower than many had previously assumed.