San Antonio Independent School District v. Rodriguez
|San Antonio Independent School District v. Rodriguez|
|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
|Prior history||Judgment for plaintiffs, 337 F. Supp. 280 (W.D. Texas (1971)|
|Subsequent history||Rehearing denied, 411 U.S. 959 (1973)|
|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.|
|Majority||Powell, joined by Burger, Stewart, Rehnquist, Blackmun|
|Dissent||White, joined by Douglas, Brennan|
|Dissent||Marshall, joined by Douglas|
|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 held the San Antonio Independent School District's financing system, based on local property taxes, was not an unconstitutional violation of the Fourteenth Amendment's equal protection clause. The majority opinion, reversing the District Court, stated the appellees did not sufficiently prove that education is a fundamental right, that textually existed within the U.S. Constitution, and could thereby (through the 14th Amendment to the Constitution), be applied to the several States. The Court also found the financing system was not subject to strict scrutiny.
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:
- 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.
- 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 the right to be educated (either as a school-age child, or an uneducated adult), was “neither ‘explicitly or implicitly’, texturally found anywhere in the U.S. Constitution. It was therefore, not anywhere protected by 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 for this ruling, also decided to foreclose for itself the Court's past quasi-constitutional amendment proposal & ratification process. In that process the Court would find post-hoc; and in its ruling ratify, long-established legislative policies as embodying a previoulsy unrecognied (and unknown) constitutional right, that would in effect become recognized as a constitutional “right” protected for the people in the States in dealing with the Federal government as a newly recognized fundamental right subject judicial recognition and enforcement by the application of the Fourteenth Amendment Due Process Clause. Since this ruling, no "new" constitutionally protected rights have been "discovered" in the U.S. Constitution.
- 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.
- Serrano v. Priest a decision contrary to Rodriguez in which California courts found that the method of funding schools violated the California Constitution's equal protection clause.
- List of United States Supreme Court cases, volume 411
- 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 0-292-71411-4.
- Sutton, Jeffrey S. (2008). "San Antonio Independent School District v. Rodriguez and Its Aftermath". Virginia Law Review 94 (8): 1963–1986.
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- ^ Text of San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973) is available from: Findlaw Justia