San Antonio Independent School Dist. v. Rodriguez

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.

Facts. Mexican-American parents of children in the Edgewood School District in San Antonio sued on behalf of children of poor families residing in districts having a low property tax base. The challengers attacked the constitutionality of the Texas system of financing public education, which relied heavily on such property taxes. Specifically, the challengers claimed that the system violated equal protection because it produced substantial inter-district disparities in per-pupil expenditures, stemming from the differences in property values among the district. Although contributions from a statewide “minimum foundation school program” served to reduce inter-district disparities, district spending continued to vary considerably on the basis of property wealth. The District Court, exercising strict scrutiny, held that the Texas scheme violated equal protection.

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.

Dissent. Requiring the state to establish only that unequal treatment is in the furtherance of a permissible goal, without also requiring the state to show that the means chosen to effectuate that goal are rationally related to its achievement, makes equal protection analysis no more than an empty gesture.
This Court has consistently adjusted the care with which it will review state discrimination in light of the constitutional significance of the interests affected and the invidiousness of the particular classification. However, the majority suggests that a variable standard of review would give this Court the appearance of a “super-legislature.” Any substantial degree of scrutiny reveals that the state has selected means wholly inappropriate to secure its purported interest in assuring its school districts local fiscal control.
Concurrence. Any other course taken by the majority would mark an extraordinary departure from principled adjudication under equal protection.

Discussion. This case is important because it holds that education is not a fundamental right. Therefore, minimum rationality is the test in cases where there are education-based classifica