San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973)
Property taxes may properly be used to fund public schools without violating the Equal Protection Clause.
The Edgewood Independent School District struggled to raise money to finance its schools through tax revenues because its generally poor population provided a weak tax base. As a result, the quality of the instructors, facilities, and equipment at its schools fell well short of the standards met by schools in other school districts. For example, districts in the northern areas of San Antonio, such as Alamo Heights, produced a stronger tax base that could contribute much more substantial tax payments per child. These districts also were predominantly white, whereas Edgewood was predominantly non-white, although this was not a central issue in the case.
The Edgewood Concerned Parent Association brought a claim against several surrounding school districts and the state, arguing that education was a fundamental right and that the Fourteenth Amendment prohibited the current Texas system of school financing, which was based on the wealth of the respective districts. They were successful against the state throughout the lower courts, which invalidated the funding system.
- Lewis Franklin Powell, Jr. (Author)
- Warren Earl Burger
- Potter Stewart
- William Hubbs Rehnquist
- Harry Andrew Blackmun
Ruling that education is not a fundamental right, the majority held that heightened scrutiny did not apply. There was no reference to it in the text of the Constitution or the Bill of Rights. As a result, Powell found that the Texas financing system was constitutional under a deferential rational basis review, since it bore a reasonable connection to a legitimate state interest. He also was reluctant to find that poverty was a suspect class under the Equal Protection Clause. More broadly, Powell disapproved of extending the scope of fundamental rights implied from the Constitution by long-standing and widespread legislative policies. His narrower view marked the end of the era in which the Court expanded the scope of due process and equal protection under the Fourteenth Amendment, and those boundaries have remained largely the same since.
- Byron Raymond White (Author)
- William Orville Douglas
- William Joseph Brennan, Jr.
- Thurgood Marshall (Author)
- William Orville Douglas
- William Joseph Brennan, Jr. (Author)
Since the fundamental rights guaranteed by the Fourteenth Amendment do not include education, the Court technically will use rational basis as the standard of review for classifications related to education. Its jurisprudence in this area has not always been consistent and predictable, however, so a slightly elevated standard may be used implicitly depending on the composition of the Court at the time.
U.S. Supreme CourtSan Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973)
San Antonio Independent School District v. Rodriguez
Argued October 12, 1972
Decided March 21, 1973
411 U.S. 1
The financing of public elementary and secondary schools in Texas is a product of state and local participation. Almost half of the revenues are derived from a largely state-funded program designed to provide a basic minimum educational offering in every school. Each district supplements state aid through an ad valorem tax on property within its jurisdiction. Appellees brought this class action on behalf of school children said to be members of poor families who reside in school districts having a low property tax base, making the claim that the Texas system's reliance on local property taxation favors the more affluent and violates equal protection requirements because of substantial inter-district disparities in per-pupil expenditures resulting primarily from differences in the value of assessable property among the districts. The District Court, finding that wealth is a "suspect" classification and that education is a "fundamental" right, concluded that the system could be upheld only upon a showing, which appellants failed to make, that there was a compelling state interest for the system. The court also concluded that appellants failed even to
demonstrate a reasonable or rational basis for the State's system.
1. This is not a proper case in which to examine a State's laws under standards of strict judicial scrutiny, since that test is reserved for cases involving laws that operate to the disadvantage of suspect classes or interfere with the exercise of fundamental rights and liberties explicitly or implicitly protected by the Constitution. Pp. 411 U. S. 18-44.
(a) The Texas system does not disadvantage any suspect class. It has not been shown to discriminate against any definable class of "poor" people or to occasion discriminations depending on the relative wealth of the families in any district. And, insofar as the financing system disadvantages those who, disregarding their individual income characteristics, reside in comparatively poor school districts, the resulting class cannot be said to be suspect. Pp. 411 U. S. 18-28.
(b) Nor does the Texas school financing system impermissibly interfere with the exercise of a "fundamental" right or liberty. Though education is one of the most important services performed by the State, it is not within the limited category of rights recognized by this Court as guaranteed by the Constitution. Even if some identifiable quantum of education is arguably entitled to constitutional protection to make meaningful the exercise of other constitutional rights, here there is no showing that the Texas system fails to provide the basic minimal skills necessary for that purpose. Pp. 411 U. S. 29-39.
(c) Moreover, this is an inappropriate case in which to invoke strict scrutiny, since it involves the most delicate and difficult questions of local taxation, fiscal planning, educational policy, and federalism, considerations counseling a more restrained form of review. Pp. 411 U. S. 40-44.
2. The Texas system does not violate the Equal Protection Clause of the Fourteenth Amendment. Though concededly imperfect, the system bears a rational relationship to a legitimate state purpose. While assuring a basic education for every child in the State, it permits and encourages participation in and significant control of each district's schools at the local level. Pp. 411 U. S. 44-53.
337 F. Supp. 280, reversed.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, BLACKMUN, and REHNQUIST, JJ., joined.
STEWART, J., filed a concurring opinion, post, p. 411 U. S. 59. BRENNAN, J., filed a dissenting opinion, post, p. 411 U. S. 62. WHITE, J., filed a dissenting opinion, in which DOUGLAS and BRENNAN, JJ., joined, post, p. 411 U. S. 63. MARSHALL, J., filed a dissenting opinion, in which DOUGLAS, J., joined, post, p. 411 U. S. 70.