San Antonio Independent School District v. Demetrio P. Rodriguez et al., 411 US 1 (1973)
Class action alleging that the Texas system for financing public schools violates the Equal Protection Clause of the 14th Amendment of the United States Constitution; Whether there is a fundamental right to education under the U.S. Constitution; Whether the poor constitute a "suspect class" activating the Equal Protection Clause; Equality/non-discrimination; Right to education; Children's rights.
This was a class action brought on behalf of children residing in a school district with a comparatively low property tax base - 98% of whom were Mexican-American. The plaintiffs challenged the reliance of the State of Texas on local property taxes to finance schools, which meant that students in poorer districts received only two-thirds of the amount students received in the wealthier districts. The plaintiffs argued this created a classification of individuals based on income and because it was an action by the State, it was in violation of the Equal Protection Clause of the 14th Amendment.
The Court concluded that the regime was constitutional. If the classification of individuals does not affect a fundamental right or create a "suspect class," (as defined by historical or other identifiable disadvantages) then the Equal Protection Clause only requires that the classification reasonably relates to a legitimate state interest. The Court determined here that it had not been shown that the state regime discriminated against any definable class of "poor" people, as the classification was done at the district rather than the individual level. Also, the court found that no "fundamental liberty interest" was threatened because although education is an important state function, it is not a right that has ever been found by that Court to be a part of the Constitution. Moreover, they found that even if one could find that there was a right to some basic level of education to be able to utilize other constitutional rights, this was not an issue in this case because basic education is provided in all school districts in Texas. There were four dissenting opinions, Justices Marshall, White, Douglas and Brennan, who argued that the Texas system for school funding lacked any rational basis and that access to education should be evaluated strictly because it is inseparably linked to the right to participate in the electoral process and to the rights of free speech and association, which are fundamental rights protected under the US Constitution.
Keywords: San Antonio Independent School District v. Demetrio P. Rodriguez et al., 411 US 1 (1973), Poverty
The Rodriguez v. San Antonio case was followed by a series of decisions by the Texas Supreme Court known as the Edgewood decisions which challenged the equity of the school financing system. The Supreme Court, ruling in favor of the plaintiffs in Edgewood Independent School District v. Kirby, 777 S.W. 2d 391 (Tex. 1989), found the system used for funding the Texas school system unconstitutional. Thus, in 1993 the Texas Legislature created a finance system based on tiered allocation formulas and recapture of revenues from the wealthiest districts. In 1995, Edgewood IV, an attempt to challenge the newly introduced system, failed. The Supreme Court of Texas held that the system was constitutional because it gave rich and poor school districts substantially equal access to the necessary funds. The remaining disparities in the levels of tax revenue needed in each district to generate the necessary funds were seen as acceptable by the Court.
In the 2005 West Orange-Cove Consolidated ISD v. Neeley case, the Texas Supreme Court found that the existing system, in which local property tax was used to fund the school system, had developed into a statewide property tax, which is prohibited by the Texas Constitution. In a ruling issued November 22, 2005, the court extended the effective date of the district court's restriction on the system until June 1, 2006, to give the Legislature time to address the issue. On May 26, 2006, the district court lifted the restriction based on steps taken by the Legislature to reduce the state's reliance on property taxes for funding education.
Cases of this sort have been litigated in many states within the U.S. with very different outcomes. For example in Serrano vs. Priest (California), the state Supreme Court decided in favor of the plaintiffs based on the equal protection argument, disregarding the states claim that it was important for local government to retain control and decision-making of school financing. In Robinson vs. Cahil (New Jersey), the state Supreme Court found that the New Jersey school finance system violated the state's education clause based on clauses requiring a thorough and efficient system of education. The Court argued that the extremely high disparities in school funding between districts created a situation where education was not being provided to all students in a thorough manner.
American Civil Liberties Union, www.aclutx.org. NAACP Legal Defense and Education Fund, http://www.naacpldf.org. National Education Association, www.nea.org.
This case is a classic articulation of a narrow approach to the interpretation of Equal Protection under the US Constitution. The final decision in the San Antonio Case in 1973 by the U.S. Supreme Court declared that education is not a "fundamental interest" under the Constitution and that it was essentially a state issue. Henceforth, school finance lawsuits have been argued in state, rather than federal courts.
