Martinez v. Bynum

In rendering their decision, the U.S. Supreme Court chose to consider the residence of a child's parents or legal guardians as justifiable criteria for determining eligibility and, therefore, access to free public education. The justices did not accept the broader claim of the petitioner that the child was eligible to free public education, regardless of residence of parents, because the student was a legal U.S. citizen who intended to indefinitely reside in the respective school district. Neither did the Court consider that if public school funding/appropriations were commonly funded through property tax receipts within individual school districts, then the rationale of domicile may have been (as Justice Marshall contended) a more dubious criteria than considering "residence" as defined in the Texas Supreme Court ruling in Snyder v. Pitts. As such, the majority justices returned to a tradition of jurisprudence (more common in the nineteenth century) which tended to privilege and recognize the sovereignty of individual states with respect to internal matters such as the education of its residents.

The district court, the court of appeals, and the U.S. Supreme Court held that the Texas statute did not violate the Fourteenth Amendment, as petitioner Oralia Martinez claimed. They found that the statute was narrowly tailored, carefully designed, and justified by the state's interest to preserve financial funds for residents closely related to the state. But the dissenting opinion of Justice Marshall challenged the constitutionality of the statute and justification of the bona fide residence requirements. His opinion could support the changes that were necessary regarding the rights of the school-age children in the field of the tuition-free public primary education.