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411 U.S. 1, *; 93 S. Ct. 1278, **;
36 L. Ed. 2d 16, ***; 1973 U.S. LEXIS 91
3 of 44 DOCUMENTS
SAN ANTONIO INDEPENDENT SCHOOL DISTRICT ET AL. v. RODRIGUEZ ET AL.
No. 71-1332
SUPREME COURT OF THE UNITED STATES
411 U.S. 1; 93 S. Ct. 1278; 36 L. Ed. 2d 16; 1973 U.S. LEXIS 91
Argued October 12, 1972
March 21, 1973
PRIOR HISTORY: APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS
DISPOSITION: The Court reversed the decision of the lower court, which held that the Texas school finance system was unconstitutional under the Equal Protection Clause of the Fourteenth Amendment.
CASE SUMMARY:
PROCEDURAL POSTURE: Defendant State of Texas appealed a decision from the United States District Court for the Western District of Texas, which held the Texas school finance system unconstitutional under the Equal Protection Clause of the Fourteenth Amendment, in plaintiff parents' class action on behalf of school children throughout Texas who were members of minority groups, or who were poor and resided in school districts having a low property tax base.
OVERVIEW: In a suit by plaintiff parents on behalf of school children throughout Texas who were members of minority groups, or who were poor and resided in school districts having a low property tax base, the lower court held that the Texas school finance system was unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. The lower court based its decision on the substantial inter-district disparities in school expenditures largely attributable to differences in the amounts of money collected through local property taxation. On appeal, the Supreme Court held that where wealth was involved, the Equal Protection Clause did not require absolute equality or precisely equal advantages. The Court found that the Texas system did not operate to the peculiar disadvantage of any suspect class. The Court rejected the lower court's finding that education was a fundamental right or liberty. The strict scrutiny test was inappropriate and applied a standard of review that required only that the State's system be shown to bear some rational relationship to legitimate State purposes. The Texas plan satisfied the standard, and thus, the Court reversed.
OUTCOME: The Court reversed the decision of the lower court, which held that the Texas school finance system was unconstitutional under the Equal Protection Clause of the Fourteenth Amendment.
CORE TERMS: educational, wealth, school districts, financing, pupil, classification, expenditure, public education, disparity, teacher, property tax, finance, funding, equal protection, per-pupil, disadvantaged, taxation, correlation, taxable property, public school, salary, tax rate, local control, judicial scrutiny, discriminatory, interdistrict, state interest, guaranteed, school funds, school year
LexisNexis(R) Headnotes
Education Law > Departments of Education > State Departments of Education > Authority
[HN1] See Tex. Const. art. X, ß 1 (1845).
Education Law > Departments of Education > State Departments of Education > Authority
[HN2] See Tex. Const. art. X, ß 2 (1845).
Civil Rights Law > General Overview
[HN3] The traditional indicia of suspectness include whether a class is saddled with disabilities, or subjected to a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process.
Civil Rights Law > General Overview
[HN4] Wealth discrimination alone does not provide an adequate basis for invoking strict scrutiny.
Education Law > Departments of Education > State Departments of Education > Authority
[HN5] It is doubtful that any child may reasonably be expected to succeed in life if he is denied the opportunity of an education. Such an opportunity, where the state has undertaken to provide it, is a right which must be made available to all on equal terms.
Constitutional Law > Equal Protection > Level of Review
Constitutional Law > Equal Protection > Scope of Protection
[HN6] The importance of a service performed by the state does not determine whether it must be regarded as fundamental for purposes of examination under the Equal Protection Clause of the Fourteenth Amendment.
Constitutional Law > Equal Protection > Scope of Protection
[HN7] The Supreme Court does not pick out particular human activities, characterize them as "fundamental," and give them added protection. To the contrary, the Court simply recognizes an established constitutional right, and gives to that right no less protection than the Constitution itself demands.
Civil Procedure > Trials > Jury Trials > Province of Court & Jury
Constitutional Law > Equal Protection > Scope of Protection
Transportation Law > Right to Travel
[HN8] It is not the province of the Supreme Court to create substantive constitutional rights in the name of guaranteeing equal protection of the laws. Thus, the key to discovering whether education is "fundamental" is not to be found in comparisons of the relative societal significance of education as opposed to subsistence or housing. Nor is it to be found by weighing whether education is as important as the right to travel. Rather, the answer lies in assessing whether there is a right to education explicitly or implicitly guaranteed by the Constitution.
Constitutional Law > Equal Protection > Scope of Protection
[HN9] Since the members of a legislature necessarily enjoy a familiarity with local conditions which the Supreme Court cannot have, the presumption of constitutionality can be overcome only by the most explicit demonstration that a classification is a hostile and oppressive discrimination against particular persons and classes.
Constitutional Law > Equal Protection > Scope of Protection
Education Law > Departments of Education > State Departments of Education > Authority
[HN10] The very complexity of the problems of financing and managing a statewide public school system suggests that there will be more than one constitutionally permissible method of solving them, and that, within the limits of rationality, the legislature's efforts to tackle the problems should be entitled to respect.
Constitutional Law > The Judiciary > Case or Controversy > Constitutionality of Legislation > General Overview
[HN11] Questions of federalism are always inherent in the process of determining whether a state's laws are to be accorded the traditional presumption of constitutionality, or are to be subjected instead to rigorous judicial scrutiny.
Constitutional Law > Equal Protection > Scope of Protection
[HN12] Only where state action impinges on the exercise of fundamental constitutional rights or liberties must it be found to have chosen the least restrictive alternative.
Constitutional Law > Equal Protection > Scope of Protection
Education Law > Funding > Allocation
Energy & Utilities Law > Financing > General Overview
[HN13] It has simply never been within the constitutional prerogative of the Supreme Court to nullify statewide measures for financing public services merely because the burdens or benefits thereof fall unevenly depending upon the relative wealth of the political subdivisions in which citizens live.
Constitutional Law > Equal Protection > Level of Review
Constitutional Law > Equal Protection > Scope of Protection
[HN14] The constitutional standard under the Equal Protection Clause of the Fourteenth Amendment is whether the challenged state action rationally furthers a legitimate state purpose or interest.
SUMMARY: A class action on behalf of certain Texas school children was instituted against state school authorities in the United States District Court for the Western District of Texas, the plaintiffs challenging the constitutionality, under the equal protection clause of the Fourteenth Amendment, of the state's statutory system for financing public education which authorizes an ad valorem tax by each school district on property within the district to supplement educational funds received by each district from the state, and which thus results in substantial interdistrict disparities in per-pupil expenditures attributable chiefly to the differences in amounts received through local property taxation because of variations in the amount of taxable properties within each district. The three-judge District Court held that the Texas school financing system discriminated on the basis of wealth and was unconstitutional under the equal protection clause, ruling that (1) wealth was a suspect classification, and education was a fundamental interest, thus requiring the state to show, under the strict judicial scrutiny test, a compelling state interest for its system, which the state had failed to do, and (2) in any event, the state had failed to establish even a reasonable basis for its system (337 F Supp 280).
On direct appeal, the United States Supreme Court reversed. In an opinion by Powell, J., expressing the views of five members of the court, it was held that (1) the strict judicial scrutiny test, which was appropriate when state action impinged on a fundamental right or operated to the disadvantage of a suspect class--under which strict test the Texas financing system would have been unconstitutional--was not applicable on the theory that the system disadvantaged a suspect class by discriminating on the basis of wealth, since there was no showing that any definable category of "poor" persons was discriminated against, that any children were suffering an absolute deprivation of public education, or that there was any comparative discrimination based on relative family income within districts, and since any "district" wealth discrimination against residents of less wealthy districts did not meet the criteria of a suspect class, (2) the financing system did not impinge on any fundamental right so as to call for application of the strict judicial scrutiny test, since education was not a right afforded explicit or implicit protection under the Constitution, and since even assuming that some identifiable quantum of education was a constitutionally protected prerequisite to meaningful exercise of the right of free speech and the right to vote, nevertheless the system did not deny educational opportunities to any child, and there was no showing that the system failed to provide an adequate education for all children, (3) the traditional standard of review under the equal protection clause, requiring a showing that the state's action had a rational relationship to legitimate state purposes, was applicable, particularly in view of the court's traditional deference to state legislatures in the areas of fiscal and educational policies and local taxation, and in view of the case's great potential impact as to principles of federalism, and (4) under the traditional equal protection test, the Texas financing system, despite its conceded imperfections, rationally furthered a legitimate state purpose, and thus did not violate the equal protection clause, since the system, by its provision for state contributions to each district, assured a basic education for every child, while permitting and encouraging vital local participation and control of schools through district taxation, and since the system, which was similar to systems employed in virtually every other state, was not the product of purposeful discrimination against any class, but instead was a responsible attempt to arrive at practical and workable solutions to educational problems.
Stewart, J., concurring, stated that (1) the Texas system did not create the kind of objectively identifiable classes that were cognizable under the equal protection clause, (2) even assuming the existence of such discernible categories, the classifications were not based upon constitutionally "suspect" criteria, (3) the financing system did not rest on grounds wholly irrelevant to the achievement of the state's objective, and (4) the system impinged on no substantive constitutional rights or liberties.
Brennan, J., dissented, stating that (1) the Texas statutory scheme was devoid of any rational basis, thus being violative of the equal protection clause, and (2) since education was inextricably linked to the right to participate in the electoral process and to the rights of free speech and association, any classification affecting education should be subjected to strict judicial scrutiny, under which the Texas system was also unconstitutional.
White, joined by Douglas and Brennan, JJ., dissented on the ground that even though local control of education might be a legitimate goal of a school financing system, nevertheless the means chosen to effectuate such goal must be rationally related to its achievement, and the Texas system unconstitutionally discriminated against parents and children who resided in property-poor districts, which districts had no meaningful chance to supplement minimum state funds to the same extent as more affluent districts.
Marshall, J., joined by Douglas, J., dissenting, expressed the views that (1) the Texas financing scheme discriminated from a constitutional perspective against the identifiable class of school children residing in property-poor districts, (2) strict judicial scrutiny of state classifications under the equal protection clause should depend on the constitutional and societal importance of the interest adversely affected and the invidiousness of the basis upon which the classification was drawn, not merely on whether the fundamental right involved was explicitly or implicitly guaranteed by the Constitution, (3) in view of the close nexus between education and the constitutionally protected rights of free speech and association and the right to vote, the Texas system should be subjected to exacting judicial scrutiny, particularly since the system's discrimination on the basis of district or group wealth created a classification of a suspect character, (4) in all equal protection cases, the court should consider the substantiality of the state interest sought to be served, scrutinizing the reasonableness of the means by which the state sought to advance its interest, (5) although local control of education constituted a substantial state interest, nevertheless such interest did not justify the Texas system's discrimination in educational opportunity, since there was no possible local control over the amount of property located in a district, the means selected thus being wholly inappropriate to secure the state's purported interest in assuring school districts local fiscal control, and (6) the wide disparities in taxable district property wealth inherent in the local property tax element of the Texas system rendered the system violative of the equal protection clause in view of the denial to children in property-poor districts of equal educational opportunities.
LAWYERS' EDITION HEADNOTES:
[***LEdHN1]
COURTS ß225.6
three-judge District Court -- constitutionality of state statutes --
Headnote:[1A][1B]
A three-judge Federal District Court is properly convened under 28 USCS 2281 in an action by parents of school children against state officials attacking the constitutionality under the equal protection clause of the Fourteenth Amendment of the state's statutory system for financing public education.
[***LEdHN2]
LAW ß345
equal protection -- school financing system --
Headnote:[2A][2B][2C]
In determining the validity, under the equal protection clause of the Fourteenth Amendment, of a state's statutory system for financing public education which authorizes an ad valorem tax by each school district on property within the district to supplement educational funds received by the district from the state, and which thus results in substantial interdistrict disparities in per-pupil expenditures attributable primarily to the differences in amounts received through local property taxation because of the variations in the amount of taxable properties within each district--such system being challenged as subjecting children in less affluent districts to invidious discrimination--the proper standard of judicial review is the traditional standard requiring that the system be shown to bear some rational relationship to a legitimate state purpose, rather than the strict judicial scrutiny standard requiring the showing of a compelling state interest, under which strict standard the system would be unconstitutional; under the traditional standard of review, the state's financing system, despite its conceded imperfections, rationally furthers a legitimate state purpose or interest, and thus is not violative of the equal protection clause, where (1) the system's provisions for state contribution of funds to each district was designed to provide an adequate minimum educational offering in every school, the system thus assuring a basic education for every child while permitting and encouraging a large measure of vital participation in and control of each district's schools at the local level, and (2) the system, which was similar to systems in virtually every other state, was not the product of purposeful discrimination against any group, but instead was rooted in decades of experience, was in the major part the product of responsible studies by qualified persons, and was, at every stage of its development, a rough accommodation of interests in an effort to arrive at a practical and workable solution of a problem for which there was no perfect solution.
[***LEdHN3]
LAW ß345
equal protection -- financing public education --
Headnote:[3]
If a state's statutory system of financing public education operates to the disadvantage of some suspect class or impinges upon a fundamental right explicitly or implicitly protected by the Constitution, it is subject to strict judicial scrutiny in determining whether it violates the equal protection clause of the Fourteenth Amendment; if the statutory scheme does not so operate, it must still be examined to determine whether it rationally furthers some legitimate, articulated state purpose and therefore does not constitute an invidious discrimination in violation of the equal protection clause.
[***LEdHN4]
LAW ß345
equal protection -- school financing system --
Headnote:[4A][4B]
With regard to the validity, under the equal protection clause of the Fourteenth Amendment, of a state's statutory system for financing public education which authorizes an ad valorem tax by each school district on property within the district to supplement educational funds received by the district from the state, and which thus results in substantial interdistrict disparities in per-pupil expenditures attributable primarily to the differences in amounts received through local property taxation because of the variations in the amount of taxable properties within each district, such system does not operate to the peculiar disadvantage of any suspect class, discriminating on the basis of wealth, so as to require application of the strict judicial scrutiny rule under which the state must establish a compelling state interest for its actions, where (1) there was no showing that the system discriminated against any definable category of "poor" persons, or that children in districts having relatively low assessable property values were suffering an absolute deprivation of public education, (2) even assuming that a class composed of the "comparatively" poor could claim the special protection accorded "suspect" classes, nevertheless the record did not establish any relative or comparative discrimination based on family income through any correlation between the wealth of families within each district and the expenditures therein for education, and (3) any "district" wealth discrimination, that is discrimination against those who, irrespective of personal income, happen to reside in any district except the one with the most assessable property or in districts with assessable property falling below the statewide average, would not meet the criteria of a suspect class, since such a large, diverse, and amorphous class was unified only by the common factor of residence in districts that happened to have less taxable wealth than other districts.