San Antonio Independent School District v. Rodriguez
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| San Antonio v. Rodriguez | ||||||||
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 Supreme Court of the United States |
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| Argued October 12, 1972 Decided March 21, 1973 |
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| Holding | ||||||||
| Reliance on property taxes to fund public schools does not violate the Equal Protection Clause even if it causes inter-district expenditure disparities. Absolute equality of education funding is not required and a state system that encourages local control over schools bears a rational relationship to a legitimate state interest. District Court of Texas reversed. | ||||||||
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| Laws applied | ||||||||
| U.S. Const. amend. XIV |
San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973), was a case in which the Supreme Court of the United States reversed a Texas three-judge District Court.
The Supreme Court's decision held that a school-financing system based on local property taxes was not an unconstitutional violation of the Fourteenth Amendment's equal protection clause. The majority opinion stated that the appellees did not sufficiently prove that education is a fundamental right or that the financing system was subject to strict scrutiny.
The District Court had decided that education is a fundamental right and that the financing system was subject to strict scrutiny.
[edit] Background
This lawsuit was brought by members of the Edgewood Concerned Parent Association representing their children and similarly situated students. The suit was filed on June 30, 1968 in the federal district court for the Western District of Texas. In the initial complaint, the parents sued San Antonio ISD, Alamo Heights ISD and five other school districts, the Bexar County School Trustees and the State of Texas contending the “Texas method of school financing violated the equal protection clause of the Fourteenth Amendment to the U. S. Constitution.” The lawsuit alleged that education was a fundamental right and that wealth-based discrimination was a constitutionally suspect class. Eventually, the school districts were dropped from the case leaving only the State of Texas as the defendant. The case advanced through the courts system, providing victory to the Edgewood parents until it reached the Supreme Court in 1972. The school districts in the San Antonio area, and generally in Texas, had a long history of financial inequity. Rodriguez presented evidence that school districts in the wealthy, and primarily white, areas of town, most notably the north-side Alamo Heights Independent School District, were able to contribute a much higher amount per child than Edgewood, which was a poor minority area. From the trial brief, Dr. Jose Cardenas, Superintendent of Schools, Edgewood Independent School District testified to the problem in his affidavit, the following information:
1 “Edgewood is a poor district with a low tax base. As a result, its ad valorem tax revenue fall far short of the monies available in other Bexar County school districts. With this inequitable financing of its schools, Edgewood cannot hire sufficient qualified personnel, nor provide the physical facilities, library books, equipment and supplies afforded by other Bexar County District.” 2 “To illustrate the Edgewood residents are making a high tax effort, have burdened themselves with one of the highest proportion of bonded indebtness in the county to pay for capital improvements and, never, in the history of the district have they failed to approve a bond issue.”
Cardenas cites a study, A tale of Two Districts” that makes the following comparisons in 1967-8:
Northeast had 70.36 square feet classroom space Edgewood had 50.4 square feet classroom space Northeast had 9.42 library books Edgewood had 3.9 Northeast had 1/19 teacher/pupil ratio Edgewood had 1/28 Northeast had 1 counselor for every 1,553 children Edgewood had 1 for 5,672 Alamo Heights 1 for 1,319 Northeast had 8% dropout rate between 7-12 grade Edgewood had 32%
In fact, the financial disparity Edgewood and Alamo Heights increased in the four years it took for Rodriguez to work its ways through the court system, “from a $310 total per-pupil disparity in 1968 in state and local support between the districts to a $389 disparity in 1972.” In the Supreme Court, a new group of justices had been appointed since the filing of the case. The most significant new member was Justice Lewis Powell, who proved to be the swing vote in the Rodriguez case. Powell led the 5-4 majority in deciding that education was “neither ‘explicitly or implicitly’ protected in the Constitution.” He also found that Texas had not created a suspected class related to poverty. These two findings allowed the state to continue their school financing plan as long as it was “rationally related to a legitimate state interest.
[edit] External links
- ↑ 411 U.S. 1 Full text of the opinion courtesy of Findlaw.com.
- Summary of case from OYEZ
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