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New Hampshire's Commission for Human Rights, audited by the Legislature's own Office of Legislative Budget Assistant

NH Paid $2.4M for a Rights Panel That Let Cases Expire

Summary

A New Hampshire legislative audit found the state's Commission for Human Rights averaged 2.3 years to close a discrimination complaint in 2023, missing its own two-year statutory deadline on 62% of cases and letting 27% run past the three-year window New Hampshire law gives complainants to sue at all. New Hampshire's General Fund paid $2.37 million to keep the commission running from 2020 through 2023 -- more than three times what the commission earned in federal funds over the same years. Fifteen months later, the commission says cases now close in about 20 months, but it is running on seven investigators against the 14 its own chairman calls a reasonable staffing level, with three more positions still unfunded.

By Marcus Aurelius · July 20, 2026

New Hampshire's Office of Legislative Budget Assistant -- the Legislature's own audit arm, commissioned by lawmakers on the Joint Legislative Performance Audit and Oversight Committee to check whether the state's Commission for Human Rights was 'efficiently and effectively enforcing laws against discrimination' -- found it averaged 840 days, or 2.3 years, to close a discrimination complaint filed in fiscal year 2023. State law gives the Commission two years, not two-and-a-third, to close a case or start a formal hearing. The audit found 62 of the 228 cases it reviewed -- 27.2% -- took so long that complainants lost their legal window to sue in Superior Court at all.

A two-year deadline missed six times in ten

RSA 354-A:21, IV -- the statute governing New Hampshire's ban on discrimination in employment, housing, public accommodations, and K-12 education -- requires the Commission to 'close each case or commence adjudicative proceedings ... within 24 months after the filing date of the complaint', a 730-day clock. In SFY2023, it took an average of 557 days -- 1.5 years -- just to assign a filed case to an investigator; the investigation itself then averaged roughly another year. Of the 228 case files the audit reviewed, 142 -- 62.3% -- closed after that two-year target had already passed.

Average days to close a case, SFY2023
840 days
2.3 years -- 110 days past the two-year statutory target
Cases that ran out the legal clock
62 of 228
27.2% closed too late for complainants to sue -- past the 3-year statute of limitations
Cost to NH's General Fund, SFY2020-2023
$2.37M
More than 3x the $704,134 the Commission earned in federal funds over the same four years
How long a discrimination case actually took, SFY2023
Average days elapsed, against the statute's own two-year target
Statutory target (RSA 354-A:21, IV)
730
Average time to assign an investigator
557
Average time to close a case
840
Source: NH Office of Legislative Budget Assistant, Commission for Human Rights Performance Audit (Feb. 2025), Observation No. 1, pp.17,19
View data as table
The law gives the Commission two years (730 days) to close a discrimination case. In SFY2023 it averaged 840 days -- and investigators weren't even assigned, on average, until 557 days had already passed.
Statutory target (RSA 354-A:21, IV)730Two years to close a case or start a formal hearing -- the law's own deadline
Average time to assign an investigator5571.5 years just to start work on a filed case
Average time to close a case8402.3 years -- 110 days past the statutory target

For a quarter of cases, the delay itself was the verdict

New Hampshire also gives discrimination complainants a separate right under RSA 354-A:21-a: if the Commission doesn't resolve a case, a complainant can bring their own civil action in Superior Court -- but 'not later than 3 years after the alleged unlawful practice occurred'. The audit found 62 of 228 closed SFY2023 cases (27.2%) took the Commission longer than three years to resolve, meaning those complainants' own case dragging on inside the Commission was what closed the courthouse door on them. The audit noted the Commission itself argued the opposite position in 2024, telling the New Hampshire Supreme Court in an amicus brief that its two-year deadline was a 'target' rather than a firm requirement -- the Court dismissed that case as 'improvidently accepted' without ruling on the question.

What happened to the 228 cases closed in SFY2023
Reviewed case file outcomes against two separate legal deadlines
Cases reviewed, SFY2023 closures
228
Missed the 2-year statutory deadline
142
Missed the 3-year court deadline entirely
62
Source: NH Office of Legislative Budget Assistant, Commission for Human Rights Performance Audit (Feb. 2025), Observations No. 1 and No. 14, pp.19,40
View data as table
142 of 228 cases (62.3%) missed the Commission's own two-year target. For 62 of them (27.2%), the delay ran past New Hampshire's three-year statute of limitations -- closing the door to court entirely.
Cases reviewed, SFY2023 closures228The audit's full file-review sample
Missed the 2-year statutory deadline14262.3% -- closed after RSA 354-A:21's own 730-day target
Missed the 3-year court deadline entirely6227.2% -- these complainants lost the right to sue in Superior Court

$2.37 million to run an office that was 57% staffed

New Hampshire's General Fund covered a $2,373,654 shortfall between what the Commission spent and what it brought in from SFY2020 through SFY2023 -- more than three times the $704,134 the Commission earned in federal funds over those same four years. Yet as of February 2025, 12 of the Commission's 21 authorized positions sat vacant.

What New Hampshire's General Fund paid to cover the gap
Annual shortfall between Commission revenues and expenditures, charged to the General Fund
SFY2020
528,618
SFY2021
514,128
SFY2022
660,310
SFY2023
670,598
Source: NH Office of Legislative Budget Assistant, Commission for Human Rights Performance Audit (Feb. 2025), Table 1, p.14
View data as table
Federal funds covered a shrinking share of the Commission's budget every year; New Hampshire's General Fund paid $2,373,654 across SFY2020-SFY2023 to keep the office running.
SFY2020528,618
SFY2021514,128
SFY2022660,310
SFY2023670,598Four-year total: $2,373,654 -- more than three times the $704,134 the Commission earned in federal funds over the same period

One year later: better, but still short

Two lawmakers on the record captured how the audit landed: Rep. Marjorie Smith called the delays 'unconscionable', and Rep. Kenneth Weyler, who had chaired the oversight committee for more than a decade, called it 'the worst audit (result) I've ever seen'. The state's 2026 budget act, House Bill 2, created a Temporary Human Rights Commission Advisory Committee to track the fix -- reporting from its May 1, 2026 meeting found 22 of the audit's 25 recommendations had been addressed and that cases now take about 20 months to close, back under the statute's own two-year target.

  • New Hampshire's Commission for Human Rights averaged 840 days (2.3 years) to close a discrimination case in SFY2023 -- missing its own two-year (730-day) statutory deadline on 142 of 228 reviewed cases (62.3%).
  • 62 of those 228 cases (27.2%) took longer than New Hampshire's three-year statute of limitations to sue in Superior Court -- meaning the Commission's own delay is what cost those complainants their day in court.
  • New Hampshire's General Fund paid $2,373,654 to cover the Commission's budget shortfall from SFY2020-SFY2023 -- over 3x the $704,134 it earned in federal funds -- while 12 of 21 authorized staff positions sat vacant as of February 2025.
  • By May 2026, 22 of 25 audit recommendations had been addressed and case closures had fallen to about 20 months, but the Commission's chairman says its 7 filled investigator positions are still half of what a 'reasonable' staffing level (14) would be, with 3 more positions unfunded.

All figures on case timing, staffing, and Commission finances come from the New Hampshire Office of Legislative Budget Assistant's Commission for Human Rights Performance Audit Report (February 2025), including Observation No. 1 (case timing and the SFY2020-SFY2023 General Fund shortfall in Table 1, p.14), Observation No. 14 (the 62.3% two-year-deadline miss rate), Observation No. 15 (the EEOC contract shortfall), and Observation No. 18 (investigator staffing history). This piece independently recomputed the $2,373,654 four-year General Fund total from Table 1's own annual figures, the 3.4x ratio of General Fund cost to federal funds earned over the same period, and the $10,790 EEOC shortfall from the contract's per-case rate -- all reproducible from figures stated directly in the report. Current staffing and progress figures (22-of-25 recommendations, ~20-month case closures, 7 investigators, 3 unfunded positions, and all named-official quotes) come from InDepthNH.org's report on the May 1, 2026 Temporary Human Rights Commission Advisory Committee meeting.

Sources(4) ▾
  • Office of Legislative Budget Assistant, Audit Division, State of New Hampshire, New Hampshire Commission for Human Rights -- Performance Audit Report (2025-02-01)The primary document -- the New Hampshire Legislature's own performance-audit arm's statutory audit of the Commission for Human Rights, requested by the Fiscal Committee's Joint Legislative Performance Audit and Oversight Committee in January 2023 and covering SFY2020-SFY2023. Source for every case-timing, staffing, and dollar figure in this piece, plus the Commission's own written response. gc.nh.gov · original document
  • Office of Legislative Services, New Hampshire General Court, RSA 354-A:21 Procedure on Complaints (New Hampshire Revised Statutes Annotated) (2006-07-01)The controlling statute itself -- independent confirmation, straight from New Hampshire's official codified law, of the 24-month/730-day deadline the audit measured the Commission against in subsection IV. gc.nh.gov · original document
  • Office of Legislative Services, New Hampshire General Court, RSA 354-A:21-a Choice of Forum (New Hampshire Revised Statutes Annotated) (2006-07-01)The controlling statute itself -- independent confirmation, straight from New Hampshire's official codified law, of the three-year deadline for a complainant to reach Superior Court that the audit's 27.2% figure measures against. gc.nh.gov · original document
  • InDepthNH.org (New Hampshire Center for Public Interest Journalism), Advisory Panel Hears Progress Improving the NH Human Rights Commission (2026-05-01)Contemporaneous reporting on the Temporary Human Rights Commission Advisory Committee's May 1, 2026 public meeting -- the statutorily created (House Bill 2) body overseeing the Commission's response to the February 2025 audit. Source for the current staffing count, the 22-of-25-recommendations-addressed status, the ~20-month case-closure figure, and on-the-record quotes from the Commission's chairman, acting assistant director, and legislative overseers. indepthnh.org · original document
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