This case study considers why community members of two rural New York School districts reacted so strongly against a referendum for school district reorganization in February 1983. State and local school officials introduced into this reorganization effort a unique plan designed to achieve community support for the merger. Rather than have the State conduct the merger feasibility study, a Community Participation Plan organized community members into committees, each of which studied one aspect of the proposed reorganization. Despite unanimous support of all 10 community based committees, citizens overwhelmingly rejected the referendum. Study results suggest that community members were neither convinced that their school districts were inadequate nor that reorganizing would lead to important new opportunities for large numbers of students. The decision to reject reorganization appears to have had less to do with issues of community identity and more to do with costs and benefits of those opportunities. Contrary to state expectations, the more the community discussed and debated, the less possible it became for agreement to be reached. Two conclusions emerged: because they are so divisive, reorganizations should be handled quickly with a minimum of discussion and citizen involvement; or, the case for reorganization is not so compelling as its advocates believe, and the state should pursue a more balanced role in improving rural educational opportunities. (NEC)