Martinez v. Bynum

In affirming the decisions of lower courts, the Court upheld the notion of a state's right to administer internal affairs which affected all U.S. citizens living within a state's jurisdiction. Opponents of this ruling maintained that the ethnic background of their students was the "hidden" criteria by which Texas statute determined access to free education. Nonetheless, the Court's opinion made it possible for states to embark on legislative change which would not always recognize the problems of non-citizens if a state could demonstrate that legislation served a justifiable state interest.

Even though his parents were Mexican citizens who resided in Reynosa, Mexico, Roberto Morales was born in McAllen, Texas, and therefore a United States citizen by birth. At the age of seven, he left Reynosa in 1977 to live with his sister who was married and lived in McAllen. The sole purpose for his return was to gain access to tuition-free education by attending school in the McAllen Independent School District. Although his sister, Oralia Martinez, was his custodian, she was not and did not ever intend to be his legal guardian. Because, according to the Sections 21.031(b) and (c) of the Texas Education Code [hereafter referred to as Section 21.031(d)] a child was entitled to a tuition-free education only if "his parent, guardian, or person having lawful control of him" resided in the school district, Mrs. Martinez did not qualify as a person who had "lawful control" of Roberto. The McAllen Independent School District denied Morales's application for admission in the fall of 1977.

In December of 1977, Oralia Martinez and four other adult custodians of school-age children filed suit in the District Court for the Southern District of Texas against the Texas Commissioner of Education, the Texas Education Agency, four local school districts, and local school officials in each adult's respective school districts. Petitioners claimed that Section 21.031(d) violated the Constitution, including the Equal Protection Clause, the Due Process Clause, and the Privileges and Immunities Clause. Their main claims were that the traditional definition of bona fide residency was not applicable, and that statutory provisions were violative. Granting educational benefits only to children of Texas residents and children whose custodial guardians had official, legal guardianship was inconsistent with the Equal Protection Clause of the Fourteenth Amendment.

Petitioners asked for preliminary and permanent injunctive relief. In 1978, a preliminary injunction was denied by the district court. That court's findings characterized the admissions policy of the (sued) school boards as being more than liberal in accepting children into their schools. Even if their parents or legal guardians did not live in the school district children were granted admission if the reason for living apart from birth/legal parents was not strictly for the purpose of attending a particular school. In response to the court's decision, petitioners narrowed the scope of their petition to claim that Section 21.031(d) was unconstitutional on its face. Again, the district court adjudicated in favor of the respondents. On appeal, the U.S. Court of Appeals for the Fifth Circuit affirmed. Considering of the importance of the issues presented by this case, the U.S. Supreme Court agreed to consider the case on certiorari.