Plyler v. Doe

Brief Fact Summary.

In 1975 the Texas legislature passed a law withholding funds for the education of children of illegal aliens. This law also authorized local school districts to deny entry in the public schools of the state to these children.

Synopsis of Rule of Law.

In order for a state to constitutionally deny a discrete group of individuals the rights it offers to others, this denial must be justified by showing a legitimate state interest.

Facts.

In May 1975, the Texas legislature revised its education laws to withhold from local school districts any state funds for the education of children who were not legally admitted into the United States. The 1975 revision also authorized local school districts to deny enrollment in their public schools to children not legally admitted to the country.

Issue.

Whether, consistent with the Equal Protection Clause of the Fourteenth Amendment, Texas may deny to undocumented school-age children the free public education that it provides to children who are citizens of the United States or legally admitted aliens?

Held.

No. If the State is to deny a discrete group of children the free public education it offers to others residing within its borders, that denial must be justified by a showing that it furthers some substantial state interest. The state does not adequately show such an interest in this case. The state must show that its classification of a subject class has been precisely tailored to serve a compelling governmental interest. The Court finds it difficult to understand the states goals in limiting the education of children of illegal immigrants. Whatever these interests may be they are insubstantial when looking at the costs of not educating these children for the State and the Nation.

Dissent.

Finds sound policy arguments against the Texas legislature’s choice, and therefore this law is not unconstitutional. By rendering this decision the Court is compensating for the inaction of Congress, and it is not the duty of the Court to make up for the ineffectiveness of the political branches of government.
Concurrence.
The facts of this case shows the wisdom of rejecting a rigidified approach to equal protection analysis, and employing an approach that allows for varying levels of scrutiny depending on the constitutional and societal importance of the interest adversely affected and the recognized invidiousness of the basis upon which the particular classification is drawn.
When the State provides an education to some and denies it to others, it immediately and inevitably creates class distinctions of a type fundamentally inconsistent with the Equal Protection Clause. Denial of an education is the analogue of denial of the right to vote, placing these children at a permanent disadvantage similar to disenfranchisement.
The State’s denial of education to these children bears no substantial relation to any substantial state interest. It is hard to argue that anyone benefits from the creation of a subclass of illiterate persons, many of whom will remain in the State, adding to the problems and costs of both State and National Governments attendant upon unemployment, welfare, and crime.

Discussion.

This case is very similar to San Antonio Independent School District v. Rodriguez. In this case the Court, like in Rodriguez, uses the rational relationship test to determine the constitutionality of a state law impacting education. Unlike Rodriquez, the Court in this case feels that the cost of allowing this law, i.e. a large illiterate group of children, outweighs the benefits provided to the State through this law. The concurrences in this case argue for a different approach to reach the same conclusion, while the dissent feels that the Court should universally withhold judgment in those cases that are meant for the political branches of govern