Appellant
San Antonio Independent School District, et al.
Appellee
Demetrio P. Rodriguez, et al.
Appellant's Claim
The state of Texas financed public education in such a way as to discriminateagainst children living in poor school districts.
Chief Lawyer for Appellant
Charles Alan Wright
Chief Lawyer for Appellee
Arthur Gochman
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr. (writing for the Court), William H. Rehnquist, Potter Stewart
Justices Dissenting
William J. Brennan, Jr., William O. Douglas, Thurgood Marshall, Byron R. White
Place
Washington, D.C.
Date of Decision
21 March 1973
Decision
That Texas statutes which regulated the financing of public schools based onproperty taxes in each school district and resulting in per-student funding disparities between the districts did not violate the Fourteenth Amendment's Equal Protection Clause.
Significance
By refusing to overturn the Texas statutes, it also refused to contest the way most states financed public schools even though it led to discrimination against people living in poor school districts.
Since the Fourteenth Amendment was added to the Constitution in 1868, the Supreme Court has used it to help ensure the same rights to all people regardless of race. However, the issues are not always clear cut, as demonstrated in the case of San Antonio School District, et al. v. Rodriguez, et al.
Background
When Texas became a state in 1845, its first state constitution established free public schools. Soon, the state enacted a two-way method of financing schools. The state and the local school district would both contribute. By 1883,the Texas legislature amended its constitution to provide local school districts with the power to levy ad valorem taxes, to build new school buildings and to maintain existing school buildings. An ad valorem tax means the tax is calculated on a property's value--in this case, essentially a property tax.
The state's Permanent School Fund and Available School Fund supplemented whatever funding was provided locally. Public land was set aside to provide thisfund with the income necessary to support the state's public schools. The Permanent School Fund, a state ad valorem tax, and certain other taxes, provided money to the Available School Fund which actually disbursed most of the state educational funds through the rest of the nineteenth century and into the first half of the twentieth. In 1918, state property taxes were increased to help provide free textbooks to all the schools.
In its earlier history, Texas was mostly rural, helping to distribute population and property wealth throughout the state in a generally even fashion. That changed as the state became more industrialized and population shifted fromrural to urban settings.
Soon, the growing differences in population and property wealth in differentschool districts resulted in larger differences in the amounts being spent locally for education. It also began to become apparent that the Available School Fund could not fill-in the growing chasm between richer and poorer districts.
As the difference grew between the tax base of different school districts, the state designed complex formulae, such as the Gilmer-Aikin bill, that established the Texas Minimum Foundation School Program. At the time of San Antonio v. Rodriguez, this program accounted for about half of the money spent on education in Texas. This program had two goals: to place a heavier financial burden on the wealthier districts, and to make all school districts contribute to its children's education without exhausting the resources of any one district. In practice, wealthier districts had more resources to supplementstate and program funding.
Edgewood v. Alamo Heights
In San Antonio v. Rodriguez, plaintiffs lived in the Edgewood Independent School District, one of seven in the metropolitan area. It was a residential area where the student body was about 90 percent Mexican American. More than six percent were African Americans. At the time, the average assessed property value was the lowest in the metropolitan area--a mere $5,960.
This area was compared to the Alamo Heights Independent School District, thewealthiest San Antonio school district, with a primarily Caucasian population--only about 18 percent Mexican Americans and less than one percent African Americans. Its average assessed property value was $49,000.
Due to the state's formula for funding public education, with a combination of federal, state and local funding, the Edgewood School District provided $356 per student in the 1967-1968 school year while Alamo Heights provided $594per student during the same period.
What Happened
Edgewood parents brought suit against the state of Texas in the U.S. DistrictCourt for the Western District of Texas. They alleged that the Texas methodof funding public education discriminated against those children who happenedto live in poorer school districts.
The district court ruled that Texas was financing school systems in a discriminatory fashion, based on wealth. Therefore, under the Equal Protection Clause, it was an unconstitutional system. They found that wealth was a suspect classification, a factor used to determine whether a law denies a class of individuals equal protection. Suspect classifications are those based on race, alienage, national origin, and sex. Also, it was decided that education was a "fundamental right." This meant that the state had to prove that there was a "compelling state interest" which dictated its policies. In fact, according tothe district court, Texas didn't show that there was even a reasonable basisfor its school funding policies.
When appealed, the U.S. Supreme Court reversed the district court's decision.Justice Powell, expressing the views of five justices, denied both of the district court's findings. He pointed out that wealth, in and of itself, had never been a suspect classification nor had education ever been a fundamental right. He stated that these children were not being discriminated against because they were poor people, but because of where they lived.
In fact, the opinion went, nobody had shown that any group of children were being discriminated against. No children were absolutely deprived of a publiceducation. The public school funding method did not take away any fundamentalrights because education was not a constitutional right. There was no evidence that the school system provided an adequate education for all children.
Justice Powell also found that the Texas method for financing schools did notviolate the Equal Protection Clause because there was a sound, rational basis for its existence. It was shown to be helping the state solve the problem of underwriting a public education system in much the same way as virtually every other state.
Related Cases
San Antonio Independent School District, et al.
Appellee
Demetrio P. Rodriguez, et al.
Appellant's Claim
The state of Texas financed public education in such a way as to discriminateagainst children living in poor school districts.
Chief Lawyer for Appellant
Charles Alan Wright
Chief Lawyer for Appellee
Arthur Gochman
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr. (writing for the Court), William H. Rehnquist, Potter Stewart
Justices Dissenting
William J. Brennan, Jr., William O. Douglas, Thurgood Marshall, Byron R. White
Place
Washington, D.C.
Date of Decision
21 March 1973
Decision
That Texas statutes which regulated the financing of public schools based onproperty taxes in each school district and resulting in per-student funding disparities between the districts did not violate the Fourteenth Amendment's Equal Protection Clause.
Significance
By refusing to overturn the Texas statutes, it also refused to contest the way most states financed public schools even though it led to discrimination against people living in poor school districts.
Since the Fourteenth Amendment was added to the Constitution in 1868, the Supreme Court has used it to help ensure the same rights to all people regardless of race. However, the issues are not always clear cut, as demonstrated in the case of San Antonio School District, et al. v. Rodriguez, et al.
Background
When Texas became a state in 1845, its first state constitution established free public schools. Soon, the state enacted a two-way method of financing schools. The state and the local school district would both contribute. By 1883,the Texas legislature amended its constitution to provide local school districts with the power to levy ad valorem taxes, to build new school buildings and to maintain existing school buildings. An ad valorem tax means the tax is calculated on a property's value--in this case, essentially a property tax.
The state's Permanent School Fund and Available School Fund supplemented whatever funding was provided locally. Public land was set aside to provide thisfund with the income necessary to support the state's public schools. The Permanent School Fund, a state ad valorem tax, and certain other taxes, provided money to the Available School Fund which actually disbursed most of the state educational funds through the rest of the nineteenth century and into the first half of the twentieth. In 1918, state property taxes were increased to help provide free textbooks to all the schools.
In its earlier history, Texas was mostly rural, helping to distribute population and property wealth throughout the state in a generally even fashion. That changed as the state became more industrialized and population shifted fromrural to urban settings.
Soon, the growing differences in population and property wealth in differentschool districts resulted in larger differences in the amounts being spent locally for education. It also began to become apparent that the Available School Fund could not fill-in the growing chasm between richer and poorer districts.
As the difference grew between the tax base of different school districts, the state designed complex formulae, such as the Gilmer-Aikin bill, that established the Texas Minimum Foundation School Program. At the time of San Antonio v. Rodriguez, this program accounted for about half of the money spent on education in Texas. This program had two goals: to place a heavier financial burden on the wealthier districts, and to make all school districts contribute to its children's education without exhausting the resources of any one district. In practice, wealthier districts had more resources to supplementstate and program funding.
Edgewood v. Alamo Heights
In San Antonio v. Rodriguez, plaintiffs lived in the Edgewood Independent School District, one of seven in the metropolitan area. It was a residential area where the student body was about 90 percent Mexican American. More than six percent were African Americans. At the time, the average assessed property value was the lowest in the metropolitan area--a mere $5,960.
This area was compared to the Alamo Heights Independent School District, thewealthiest San Antonio school district, with a primarily Caucasian population--only about 18 percent Mexican Americans and less than one percent African Americans. Its average assessed property value was $49,000.
Due to the state's formula for funding public education, with a combination of federal, state and local funding, the Edgewood School District provided $356 per student in the 1967-1968 school year while Alamo Heights provided $594per student during the same period.
What Happened
Edgewood parents brought suit against the state of Texas in the U.S. DistrictCourt for the Western District of Texas. They alleged that the Texas methodof funding public education discriminated against those children who happenedto live in poorer school districts.
The district court ruled that Texas was financing school systems in a discriminatory fashion, based on wealth. Therefore, under the Equal Protection Clause, it was an unconstitutional system. They found that wealth was a suspect classification, a factor used to determine whether a law denies a class of individuals equal protection. Suspect classifications are those based on race, alienage, national origin, and sex. Also, it was decided that education was a "fundamental right." This meant that the state had to prove that there was a "compelling state interest" which dictated its policies. In fact, according tothe district court, Texas didn't show that there was even a reasonable basisfor its school funding policies.
When appealed, the U.S. Supreme Court reversed the district court's decision.Justice Powell, expressing the views of five justices, denied both of the district court's findings. He pointed out that wealth, in and of itself, had never been a suspect classification nor had education ever been a fundamental right. He stated that these children were not being discriminated against because they were poor people, but because of where they lived.
In fact, the opinion went, nobody had shown that any group of children were being discriminated against. No children were absolutely deprived of a publiceducation. The public school funding method did not take away any fundamentalrights because education was not a constitutional right. There was no evidence that the school system provided an adequate education for all children.
Justice Powell also found that the Texas method for financing schools did notviolate the Equal Protection Clause because there was a sound, rational basis for its existence. It was shown to be helping the state solve the problem of underwriting a public education system in much the same way as virtually every other state.
Related Cases
- Meyer v. Nebraska, 262 U.S. 390 (1923).
- Pierce v. Society of Sisters, 268 U.S. 510 (1925).
- McCollum v. Board of Education, 333 U.S. 203 (1948).
- Brown v. Board of Education, 347 U.S. 483 (1954).
- Abington School District v. Schempp, 374 U.S. 203 (1963).
- Shapiro v. Thompson, 394 U.S. 618 (1969).
- Graham v. Richardson, 403 U.S. 365 (1971).
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