Appellants
J. and R. Doe; certain named and unnamed undocumented alien children, et al.
Appellees
James L. Plyler, et al.
Appellants' Claim
That schools admitting children who could not establish that they had come into the United States legally should still receive state funding.
Chief Lawyer for Appellants
Peter D. Roos for J. and R. Doe et al., Peter A. Schey for certain named andunnamed undocumented alien children et al.
Chief Lawyer for Apellees
John C. Hardy for James L. Plyler et al.; Richard L. Arnett for State of Texas, et al.
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr. (writing for the Court), ThurgoodMarshall, Lewis F. Powell, Jr., John Paul Stevens
Justices Dissenting
Warren E. Burger, Sandra Day O'Connor, William H. Rehnquist, Byron R. White
Place
Washington, D.C.
Date of Decision
15 June 1982
Decision
That the Texas law which withheld funds from local school districts for educating children not legally admitted into the United States and the authorization of these districts to deny these children enrollment, violated the Equal Protection Clause of the Fourteenth Amendment to the Constitution.
Significance
With this decision, states could no longer withhold public education from children simply because they were illegal aliens.
Although it may seem to be a contradiction, the Constitution's Equal Protection Clause provides certain rights to illegal aliens the same as any legal alien or U.S. citizen. The case of Plyler v. Doe helped the U.S. SupremeCourt guarantee those rights through application of the Equal Protection Clause.
Toward the end of the nineteenth century, the flood of people into the UnitedStates made it necessary to begin limiting immigration. That it is illegal to enter the country without permission has not prevented uncountable masses from taking up illegal residence. Border states like California, Arizona, NewMexico, and Texas are especially susceptible to immigrants looking for a better way of life.
In May of 1975, members of the Texas legislature decided that illegal immigration was a problem, and it was necessary to change its existing education statutes. Now, the state would withhold funding from local school districts foreducating students who were not legal residents of the United States. The same ruling also allowed local school districts to decide that they could deny admission to students who were illegal residents.
In spite of the ruling, at least one school system--the Tyler Independent School District--allowed children of dubious legal residence to continue enrollment and attendance. This changed in July of 1977 when it announced that in order for these children to enroll, they would be charged a "full tuition fee."
In September of 1977, a class action was filed in the U.S. District Court forthe Eastern District of Texas for those Mexican-born, school-age children, who lived in Smith County, and could not prove legal residence in the United States. The action argued that these children were excluded from the Tyler Independent School District public schools.
The suit named as defendants both the school district's superintendent and members of the district's board of trustees. The state of Texas tried to intervene by becoming a party defendant; that is, the state wanted the rightto provide defense, cross examine witnesses and appeal from judgment.
First, the district court established that there was a class that consisted of all Mexican-born school-age children who lived in the school district. Next, the district court ruled that the defendants had to provide a free education to all members of the plaintiff class, the same as any legal United Statesresident. This was a preliminary ruling, not a permanent decision.
In December of 1977, the plaintiffs moved for permanent injunctive relief--assistance from the court to invalidate the statute and correct an injustice. In its case, the state argued that the statutes were merely ways to help avoid financial drains. The district court noted that while these laws mayindeed save money, they would not improve the quality of the education. The court also noted that it was only this one small segment of the population which had to bear the responsibilities for the school district's financial burdens. The court pointed out that although these families had immigrated to theUnited States illegally, they were here to stay and, in fact, may well be future legal residents.
Following this line of reasoning, the court said that these children were poor, lacked crucial English language skills, and were victims of widespread racial prejudice. Preventing them from attending school would only ensure that they remained at the bottom of the socio-economic ladder. The district court found that the statutes violated the Fourteenth Amendment's Equal Protection Clause which protects all illegal aliens. The district court also ruled that the Supremacy Clause had been violated, that the state law was superseded by the Immigration and Nationality Act as well as federal laws that concerned funding and educational discrimination. The court of appeals decided that the district court had misinterpreted the Supremacy Clause precedents, but agreed that the Texas laws were basically unconstitutional.
This was not the only action against Texas, however. The Judicial Panel on Multidistrict Litigation consolidated other Texas federal district court actions into one case that the U.S. District Court for the Southern District of Texas would hear. This district also confirmed that the Texas law violated the Equal Protection Clause.
Finally, the case was appealed to the U.S. Supreme Court which held the findings of the lower courts in regard to violating the Fourteenth Amendment's Equal Protection Clause. Justice Brennan wrote an opinion that was concurred byJustices Marshall, Blackmun, Powell, and Stevens. It stated that neither theimmigrant children's illegal status, nor the state's contention that its resources were limited, established a "sufficient rational basis" for the statute's discriminatory aspects. Brennan's opinion also held that the Equal Protection Clause had been violated. Justice Marshall concurred, saying he believedthat to deny public education based on class is "utterly incompatible" with the Equal Protection Clause. Justice Blackmun also concurred, saying that whena state allows some to have a public education and denies it to others, a distinction between classes is inevitable--a fundamental inconsistency with thepurpose of the Equal Protection Clause. Finally, Justice Powell agreed, stating that in his opinion, denying education to these children didn't help thestate of Texas substantially.
However, Chief Justice Burger was joined by Justice White, Justice Rehnquist,and Justice O'Connor in dissenting, saying that while it was regrettable that Congress had been lax in its enforcement of the country's immigration laws,it was not the Court's responsibility to make up for that laxity.
Related Cases
Right to a Public Education
The American people have always regarded education and the acquisition of knowledge as matters of utmost importance. Yet, the U.S. Constitution makes no mention of education and education has never been acknowledged as a protectedfundamental right.
Under the Tenth Amendment, powers not expressly claimed for the federal government became reserved for the states including creation of educational systems. By the early 1900s all states had established free public schools. However, children who were different because of race, disability, culture, language,or gender have often been denied full and fair access to educational opportunities. The tide began to turn in the landmark case of Brown v. Board of Education (1954). The Court ruled public education must be made equally available to all children. States uniformly considered education essential to the well-being of society and any child denied the opportunity of an educationis denied the chance to succeed in life. In 1975 Congress passed the Education of All Handicapped Children Act providing a free appropriate education inthe least restricted environment for all children with disabilities. During the same period, the Court required access to public education for children ofaliens, ruled that schools must provide bilingual education, and extended new educational opportunities to girls.
Sources
Heward, William L. Exceptional Children: An Introduction to Special Education. Englewood Cliffs, NJ: Merrill, 1996.
J. and R. Doe; certain named and unnamed undocumented alien children, et al.
Appellees
James L. Plyler, et al.
Appellants' Claim
That schools admitting children who could not establish that they had come into the United States legally should still receive state funding.
Chief Lawyer for Appellants
Peter D. Roos for J. and R. Doe et al., Peter A. Schey for certain named andunnamed undocumented alien children et al.
Chief Lawyer for Apellees
John C. Hardy for James L. Plyler et al.; Richard L. Arnett for State of Texas, et al.
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr. (writing for the Court), ThurgoodMarshall, Lewis F. Powell, Jr., John Paul Stevens
Justices Dissenting
Warren E. Burger, Sandra Day O'Connor, William H. Rehnquist, Byron R. White
Place
Washington, D.C.
Date of Decision
15 June 1982
Decision
That the Texas law which withheld funds from local school districts for educating children not legally admitted into the United States and the authorization of these districts to deny these children enrollment, violated the Equal Protection Clause of the Fourteenth Amendment to the Constitution.
Significance
With this decision, states could no longer withhold public education from children simply because they were illegal aliens.
Although it may seem to be a contradiction, the Constitution's Equal Protection Clause provides certain rights to illegal aliens the same as any legal alien or U.S. citizen. The case of Plyler v. Doe helped the U.S. SupremeCourt guarantee those rights through application of the Equal Protection Clause.
Toward the end of the nineteenth century, the flood of people into the UnitedStates made it necessary to begin limiting immigration. That it is illegal to enter the country without permission has not prevented uncountable masses from taking up illegal residence. Border states like California, Arizona, NewMexico, and Texas are especially susceptible to immigrants looking for a better way of life.
In May of 1975, members of the Texas legislature decided that illegal immigration was a problem, and it was necessary to change its existing education statutes. Now, the state would withhold funding from local school districts foreducating students who were not legal residents of the United States. The same ruling also allowed local school districts to decide that they could deny admission to students who were illegal residents.
In spite of the ruling, at least one school system--the Tyler Independent School District--allowed children of dubious legal residence to continue enrollment and attendance. This changed in July of 1977 when it announced that in order for these children to enroll, they would be charged a "full tuition fee."
In September of 1977, a class action was filed in the U.S. District Court forthe Eastern District of Texas for those Mexican-born, school-age children, who lived in Smith County, and could not prove legal residence in the United States. The action argued that these children were excluded from the Tyler Independent School District public schools.
The suit named as defendants both the school district's superintendent and members of the district's board of trustees. The state of Texas tried to intervene by becoming a party defendant; that is, the state wanted the rightto provide defense, cross examine witnesses and appeal from judgment.
First, the district court established that there was a class that consisted of all Mexican-born school-age children who lived in the school district. Next, the district court ruled that the defendants had to provide a free education to all members of the plaintiff class, the same as any legal United Statesresident. This was a preliminary ruling, not a permanent decision.
In December of 1977, the plaintiffs moved for permanent injunctive relief--assistance from the court to invalidate the statute and correct an injustice. In its case, the state argued that the statutes were merely ways to help avoid financial drains. The district court noted that while these laws mayindeed save money, they would not improve the quality of the education. The court also noted that it was only this one small segment of the population which had to bear the responsibilities for the school district's financial burdens. The court pointed out that although these families had immigrated to theUnited States illegally, they were here to stay and, in fact, may well be future legal residents.
Following this line of reasoning, the court said that these children were poor, lacked crucial English language skills, and were victims of widespread racial prejudice. Preventing them from attending school would only ensure that they remained at the bottom of the socio-economic ladder. The district court found that the statutes violated the Fourteenth Amendment's Equal Protection Clause which protects all illegal aliens. The district court also ruled that the Supremacy Clause had been violated, that the state law was superseded by the Immigration and Nationality Act as well as federal laws that concerned funding and educational discrimination. The court of appeals decided that the district court had misinterpreted the Supremacy Clause precedents, but agreed that the Texas laws were basically unconstitutional.
This was not the only action against Texas, however. The Judicial Panel on Multidistrict Litigation consolidated other Texas federal district court actions into one case that the U.S. District Court for the Southern District of Texas would hear. This district also confirmed that the Texas law violated the Equal Protection Clause.
Finally, the case was appealed to the U.S. Supreme Court which held the findings of the lower courts in regard to violating the Fourteenth Amendment's Equal Protection Clause. Justice Brennan wrote an opinion that was concurred byJustices Marshall, Blackmun, Powell, and Stevens. It stated that neither theimmigrant children's illegal status, nor the state's contention that its resources were limited, established a "sufficient rational basis" for the statute's discriminatory aspects. Brennan's opinion also held that the Equal Protection Clause had been violated. Justice Marshall concurred, saying he believedthat to deny public education based on class is "utterly incompatible" with the Equal Protection Clause. Justice Blackmun also concurred, saying that whena state allows some to have a public education and denies it to others, a distinction between classes is inevitable--a fundamental inconsistency with thepurpose of the Equal Protection Clause. Finally, Justice Powell agreed, stating that in his opinion, denying education to these children didn't help thestate of Texas substantially.
However, Chief Justice Burger was joined by Justice White, Justice Rehnquist,and Justice O'Connor in dissenting, saying that while it was regrettable that Congress had been lax in its enforcement of the country's immigration laws,it was not the Court's responsibility to make up for that laxity.
Related Cases
- Yick Wo v. Hopkins, 118 U.S. 356 (1886).
- Meyer v. Nebraska, 262 U.S. 390 (1923).
- 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).
- Wisconsin v. Yoder, 406 U.S. 205 (1972).
- San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973).
- Ambach v. Norwick, 441 U.S. 68 (1979).
Right to a Public Education
The American people have always regarded education and the acquisition of knowledge as matters of utmost importance. Yet, the U.S. Constitution makes no mention of education and education has never been acknowledged as a protectedfundamental right.
Under the Tenth Amendment, powers not expressly claimed for the federal government became reserved for the states including creation of educational systems. By the early 1900s all states had established free public schools. However, children who were different because of race, disability, culture, language,or gender have often been denied full and fair access to educational opportunities. The tide began to turn in the landmark case of Brown v. Board of Education (1954). The Court ruled public education must be made equally available to all children. States uniformly considered education essential to the well-being of society and any child denied the opportunity of an educationis denied the chance to succeed in life. In 1975 Congress passed the Education of All Handicapped Children Act providing a free appropriate education inthe least restricted environment for all children with disabilities. During the same period, the Court required access to public education for children ofaliens, ruled that schools must provide bilingual education, and extended new educational opportunities to girls.
Sources
Heward, William L. Exceptional Children: An Introduction to Special Education. Englewood Cliffs, NJ: Merrill, 1996.
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