San Antonio Independent School District v. Rodriguez

San Antonio Independent School District v. Rodriguez
Supreme Court of the United States
Argued October 12, 1972 Decided March 21, 1973
Full case name	San Antonio Independent School District, et al. v. Demetrio P. Rodriguez, et al.
Citations	411 U.S. 1 (more) 93 S. Ct. 1278; 36 L. Ed. 2d 16; 1973 U.S. LEXIS 91
Case history
Prior	Judgment for plaintiffs, 337 F. Supp. 280 (W.D. Texas (1971)
Subsequent	Rehearing denied, 411 U.S. 959 (1973)
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.
Court membership
Chief Justice Warren E. Burger Associate Justices William O. Douglas · William J. Brennan Jr. Potter Stewart · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist
Case opinions
Majority	Powell, joined by Burger, Stewart, Rehnquist, Blackmun
Dissent	White, joined by Douglas, Brennan
Dissent	Marshall, joined by Douglas
Dissent	Brennan
Laws applied
U.S. Const. amend. XIV

San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973)^[1], was a case in which the Supreme Court of the United States 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, that textually existed within the US Constitution, and could thereby (through the 14th Amendment to the Constitution), be applied to the several States. The Court also found that the financing system was not 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.

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 in the provision of education (e.g., a fundamental right), created in the poor, or those of lesser wealth, a constitutionally suspect class, who were to be protected from the discrimination. 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 falls 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 Districts.
2. To illustrate, the Edgewood residents are making a high tax effort, have burdened themselves with one of the highest proportion of bonded indebtedness 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 1967-68 between Edgewood and the North East Independent School District:

• Classroom space: North East had 70.36 square feet (6.537 m²) per student; Edgewood had 50.4 square feet (4.68 m²) per student
• Library books: North East had 9.42 books per student; Edgewood had 3.9 books per student
• Teacher/Pupil Ratio: North East's ratio was 1/19; Edgewood's was 1/28
• Counselor/Pupil Ratio: North East's was 1/1,553 children; Edgewood's was 1/5,672 (the nearby Alamo Heights district had a 1/1,319 ratio)
• Dropout rate, secondary students: North East's rate was 8%; Edgewood's was 32%

In fact, the financial disparity between Edgewood and Alamo Heights increased in the four years it took for Rodriguez to work its way 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 suspect class related to poverty. These two findings allowed the state to continue its school financing plan as long so it was “rationally related to a legitimate state interest.”

The Court in its analysis foreclosed for itself a quasi-constitutional amendment proposal & ratification process; in which the Court would post-hoc ratify the States’ or the US Congresses’ policy making (legislative) process as creating fundamental rights by customary use of policies that were, after a passage of time; to be interpreted as if they were texturally found in the US Constitution (based upon the states’ or the US Government’s customary implementation of the policy, e.g. public education); and then via the 14th Amendment, constitutionally interpreting such policies as being mandated upon each of the several states.

See also

• Abbott District, a legal doctrine in New Jersey state constitutional law resulting from a series of cases holding that the education of children in poor communities was unconstitutionally inadequate.
• List of United States Supreme Court cases, volume 411

Further reading

• Soltero, Carlos R. (2006). "San Antonio ISD v. Rodriguez (1973) and the search for equality in school funding". Latinos and American Law: Landmark Supreme Court Cases. Austin, TX: University of Texas Press. pp. 77–94. ISBN 0292714114. {{cite book}}: Cite has empty unknown parameter: |coauthors= (help)
• Sutton, Jeffrey S. (2008). "San Antonio Independent School District v. Rodriguez and Its Aftermath". Virginia Law Review. 94 (8): 1963–1986. {{cite journal}}: Cite has empty unknown parameters: |month= and |coauthors= (help)

External links

• ^ Text of San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973) is available from: Findlaw  Justia 

• Summary, Full Text and PDF of this case from UnitedStatesReports.org
• Summary of case from OYEZ