San Antonio Ind. School Dist. v. Rodriguez

Brief Fact Summary.

In addition to being funded through a state-funded program designed to establish a minimum educational threshold in every school, Texas public elementary and secondary schools relied on local property taxes for supplemental revenue. This funding scheme was challenged.

Synopsis of Rule of Law.

A state’s financing system based on local property taxes is not an unconstitutional violation of the Fourteenth Amendment’s Equal Protection Clause.

Facts.

Recognizing the need for increased state funding to help offset disparities in local spending because of sizable differences in the value of assessable property between local school districts, the Texas state legislature established the Minimum Foundation School Program, which accounts for approximately half of the total educational expenditures in Texas. It calls for state and local contributions to a fund earmarked specifically for teacher salaries, operating expenses, and transportation costs. The state finances approximately 80%. The districts’ share is apportioned among the school districts under a formula designed to reflect each district’s relative taxpaying ability.

Rodriguez challenged this funding scheme by arguing that it underprivileged certain schools which lacked the vast property tax base that other districts utilized.

Issue.

Does Texas’ public education finance system violate the Fourteenth Amendment’s Equal Protection Clause by failing to distribute funding equally among its school districts?

Held.

No, Texas’ public education finance system does not violate the Fourteenth Amendment’s Equal Protection Clause.

Dissent.

Justice Brennan

The Texas statutory scheme is devoid of any rational basis.

Justice Marshall

The majority’s holding is a retreat from our historic commitment to equality of educational opportunity. Fundamental interests, which call for strict scrutiny of the challenged classification, do not encompass only established rights which we are somehow bound to recognize from the text of the Constitution itself. For example, this Court has recognized the right to vote in state elections, the right to an appeal from a criminal conviction, and the right to procreate as fundamental rights enjoying full constitutional protection – none of which are found in the text of the Constitution.

Discussion.

There is no fundamental right to education in the U.S. Constitution, so strict scrutiny is not applicable. Additionally, wealth discrimination alone does not provide an adequate basis to invoke strict scrutiny.  Thus, rational basis applies. Given the similarities between Texas’ system and those in other states, Texas’ funding scheme is not “so irrational as to be invidiously discriminatory.” The Equal Protection Clause does not require absolute equality or precisely equal advantages. An equal protection violation does not arise merely because some people can obtain relatively more of a desired benefit than others.