August 1, 2006 - The State's Second Amended Complaint Filed pursuant to the Court's Order. (PDF-178KB)
July 31, 2006 - Court Order Granting the State permission to file its Second Amended Complaint to add an administrative appeal for the denial of its plan amendments. (PDF-45KB)
June 6, 2006 - The State's Second Amended Complaint (PDF-176KB)
June 6, 2006 - The State's Memorandum in Support of Motion For Leave To File Second Amended Complaint The second amended complaint is necessary to address new arguments by the Secretary, raised for the first time in her post-oral arguments briefs, that the denial of plan amendments would afford a state the opportunity for a hearing, and any denial would be subject to Administrative Procedures Act (APA) review.(PDF-37KB)
June 6, 2006 - The State's Motion To Amend Complaint The second amended complaint is necessary to add an administrative appeal for the denial of the State's plan amendments, to update the current status of state law and facts, and to clarify certain factual allegations.(PDF-20KB)
May 19, 2006 - The State's Supplemental Brief on Matters Raised During the April 28, 2006 Oral Argument In response to the issues raised during the April 28, 2006 telephonic oral argument, the State of Connecticut submitted its legal arguments is support of its opposition to the Secretary’s Motion to Dismiss and in support of the State proceeding with its case. (PDF-105KB)
March 31, 2006 - The State's 6th Circuit Amicus Brief Connecticut, Delaware, District of Columbia, Illinois, Maine, Oklahoma, and Wisconsin filed an amicus brief in the U.S. Sixth Circuit Court of Appeals on the legal interpretation of the Unfunded Mandates Provision, 20 U.S.C. Sec. 7907(a), of the No Child Left Behind Act. (PDF-143KB)
March 30, 2006 - The Department of Education's Memorandum Regarding the 1st Amended Complaint The Federal Department of Education filed a memorandum responding to the State's amended complaint and renewing the federal government's motion to dismiss. (PDF-88KB)
March 1, 2006 - NCLB Map - Connecticut Boards of Education Supporting Attorney General Blumenthal's No Child Left Behind Lawsuit against Secretary Spellings. (PDF-244KB)
February 28, 2006 - The State's Memorandum Regarding the First Amended Complaint The State explained how the First Amended Complaint addressed the Court's concerns raised during oral argument. (PDF-82KB)
February 28, 2006 - The State's First Amended Complaint (corrected copy from March 2, 2006) During the January 30, 2006 oral argument on the Secretary of Education's motion to dismiss, the Court invited the State to submit an amended complaint. The amended complaint confirms, in relevant part, that the federal government has underfunded Connecticut's NCLB-mandated annual assessments. (PDF-221KB)
January 13, 2006 - The Secretary of Education's Reply in Support of her Motion to Dismiss The Secretary submitted further argument in support of her motion. (PDF-72KB)
December 23, 2005 - The State's Opposition to the Secretary's Motion to Dismiss The State opposed the Secretary's motion, arguing that the court has jurisdiction, and that the State should prevail on the merits. (PDF-157KB)
Exhibit 1 - State Senate debate on Public Act #03-168 dated May 21st, 2003. (PDF-1,503KB)
Exhibit 2 - Legislative History - Goals 2000: Educate America Act, Pub. L. No. 103, 227 Sec. 318, 108 Stat. 186. (PDF-92KB)
Exhibit 3 - Legislative History - School-To-Work Opportunities Act, Pub. L. No. 103, 239 Sec. 604, 108 Stat. 605. (PDF-16KB)
Exhibit 4 - Legislative History - Improving America's Schools Act, Pub. L. No. 103, 382 Sec. 14512, 108 Stat. 3906. (PDF-226KB)
December 2, 2005 - The Secretary of Education's Motion to Dismiss The Secretary moved to dismiss the State's case on jurisdictional grounds and on the merits. (PDF-157KB)
August 22, 2005 - Complaint For Declaratory And Injunctive Relief On behalf of the State and the General Assembly, the Attorney General filed suit against U.S. Secretary of Education Margaret Spellings with the U.S. District Court for the District of Connecticut. The case currently is being heard by the Honorable Mark R. Kravitz, sitting in New Haven. (PDF-1,405KB)
