Carrigan v. New Hampshire Dept. of Health & Human Services
Annotate this CasePlaintiff Anna Carrigan filed suit against defendants, the New Hampshire Department of Health and Human Services and the Department’s commissioner, alleging they were failing to meet their statutory and constitutional duties as a result of their “irresponsible” spending decisions. She asserted standing under Part I, Article 8 of the New Hampshire Constitution, which provided New Hampshire taxpayers who were eligible to vote with standing to seek a declaration that the State or a local government “has spent, or has approved spending, public funds” in violation of the law. The Superior Court granted defendants’ motion to dismiss for want of standing, and plaintiff appealed. The New Hampshire Supreme Court affirmed because plaintiff failed to challenge any specific spending action or spending approval, by the Department, as necessary to maintain standing under Part I, Article 8.
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