Martinez v. Bynum

A majority of eight justices affirmed the decision of the lower courts and ruled that Section 21.031(d) contained bona fide residence requirements which satisfied constitutional standards. The justices characterized the Texas Education Code residence requirement as narrowly defined, uniformly applicable, and appropriately designed to assure that only state residents enjoyed services provided by the state of Texas. Such a requirement did not violate the Equal Protection Clause of the Fourteenth Amendment. The Court emphasized that the uniform admissions policy enforced by Texas school districts (respondents) specifically defined bona fide residence requirements for the purpose of determining eligibility of access to free public education.

In explaining their ruling, the written majority opinion cited Vladis v. Kline (1973), a case wherein the state statute contained unconstitutional enrollment criteria which created an unappealable assumption of nonresidency for state university students. Unlike Section 21.031(d) which stipulated criteria to which a parent or guardian had to adhere, the state of Connecticut denied residence status to all students who, before they applied for admission, had legal addresses outside of the state regardless of reason. Conversely, the Court concluded that because new or transient residents to Texas were not automatically rendered ineligible, the Texas Education code, did not affect the right of interstate travel. The code simply required that a person should establish residence before asking for the services that were limited to residents.

The justices for the majority believed school districts were justified in requiring that parents of school-aged children must live in the school district where a child would attend school, with intention to stay there, in order to satisfy the basic residence criteria. The Court accepted the respondents' argument that without resident requirements, the proper planning and operation of primary and secondary schools would significantly suffer. An important constitutional criteria was served--the state had authored reasonable legislation because it supported a justifiable interest to preserve state educational financial funds for Texas residents. Indeed, the justices felt that Section 21.031(d) was far more "generous" in granting benefits not only for residents, but for all children whose reason for living in a district was not exclusively limited to attending a school. A child such as Roberto Morales could attend public school in Texas without paying tuition, if his parents or legal guardians had a bona fide intention of remaining in the school district indefinitely. But moreover, the statute also granted free education to children who parents did not intend to remain in the school district indefinitely if the child was not living in the district only to attend a school (e.g., proximity to needed medical care).