Brief Fact Summary. A Texas system of financing public education was held constitutional by the Supreme Court of the United States (Supreme Court) even though it produced substantial inter-district disparities in per-pupil expenditures, stemming from the differences in property values among the district.
Synopsis of Rule of Law. Education-based classifications are not fundamental rights. Therefore, the proper judicial standard to test such classifications is minimum rationality.
Issue. Whether the Texas system of financing public education operates to the disadvantage of some suspect class?
Whether the Texas system of financing public education impinges upon a fundamental right explicitly or implicitly protected by the United States Constitution (Constitution)?
Held. No. Judgment of the District Court reversed. The system of alleged discrimination and the class it defines have none of the traditional indicia of suspectness: the class is not saddled with disabilities, or subjected to a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process. Therefore, the Texas system does not operate to the peculiar disadvantage of any suspect class
No. Judgment of the District Court reversed. The key to discovering whether education is “fundamental” is not to be found in comparisons of the relative societal significance of education as opposed to subsistence or housing. Rather, the answer lies in assessing whether there is a right to education explicitly or implicitly guaranteed by the Constitution. Education is not among the rights afforded explicit protection under the Constitution. Nor is there any basis saying it is implicitly protected. Therefore, education is not a “fundamental” right.
The majority in Rodriguez expressly noted that every claim arising under the Equal Protection Clause has implications for the relationship between national and state power under our federal system, adding that it would be difficult to imagine a case having a greater potential impact on our federal system than the one now before us, in which we are urged to abrogate systems of financing public education presently in existence in virtually every State.View Full Point of Law