San Antonio Independent School District v. Rodriguez, No. 71-1332 Supreme Court of the United States 411 U.S. 1; 93 S. Ct. 1278; 1973 U.S.
Argued October 12, 1972
March 21, 1973
CORE TERMS: educational, wealth, financing, classification, pupil, expenditure, disparity, taxation, teacher, per-pupil, funding, election, disadvantaged, correlation, Constitutional Law, interdistrict, Fourteenth Amendment, salary, variations, discriminatory, property-poor, guaranteed, fiscal, median, finance, valorem, voter, indigent, poorest, inequality
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 challenged the constitutionality, under the Equal Protection clause, of using property tax in each district to supplement educational funds. The three-judge District Court held that the Texas school financing system was unconstitutional under the Equal Protection clause because it discriminated on the basis of wealth and was unconstitutional under the Equal Protection clause. On direct appeal, the United States Supreme Court reversed the holding.
The court in a 5-4 decision by Justice Powell held:
Wealth did not constitute a suspect class and thus the strict scrutiny test, which was appropriate when state action impinged on a fundamental right or operated to the disadvantage of a suspect class, was not applicable in this case.
The financing method employed did not impinge on any fundamental right so as to call for the application of the strict judicial scrutiny test. In addition, the court did not view education as a fundamental right which afforded explicit or implicit protection under the Constitution.
The Court then applied the traditional standard of review which requires a showing that the state's action had a rational relationship to legitimate state purposes. It found that the financing method used satisfied this test , namely in the areas of fiscal policy and educational requirements. This result was achieved despite the inherent and somewhat obvious imperfections in the current system – However, it was not up to the Court to measure the quality of system, only its constitutionality.
Stewart, J., concurring,
The financing method utilized by the Texas system did not create the kind of objectively identifiable classes that were cognizable under the Equal Protection clause and the chosen methodology did not impinge on any substantive constitutional rights or liberties.
Justice Stewart also found that the financing system did not rest on grounds wholly irrelevant to the achievement of the state's objective
Brennan, J., dissenting,
The Texas statutory scheme lacked any rational basis and was thus violative of the Equal Protection clause and the rationality test.
In addition, Justice Brennan argued that education should be evaluated under the strict scrutiny test because it was inextricably linked to the right to participate in the electoral process and to the rights of free speech and association.
Marshall, J., joined by Douglas, J., dissenting
The application of the strict judicial scrutiny test to state classifications under the Equal Protection clause should depend on the constitutional and societal importance of the interests affected and the invidiousness of the basis upon which the classification was drawn, and not merely on whether the fundamental right involved was explicitly or implicitly guaranteed by the Constitution.
Given the close nexus between education and the constitutionally protected rights of free speech and association and the right to vote, the Texas statutory scheme should be subjected to exacting judicial scrutiny.
The Court should examine the means used by a state to effectuate their goals.
The wide disparities in taxable district property that are inherent in the local property tax element of the Texas system rendered the system violative of the Equal Protection clause because it denied children in property-poor districts equal educational opportunities.
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