San Antonio Independent School Dist. v. Rodriguez

Brief Fact Summary. The State of Texas disproportionately distributes public school funds based on the amount of property tax generated in a particular area. Parents of students in low income areas protested this allotment and filed suit to eliminate this system of distribution for one that distributes money equally in all areas.

Synopsis of Rule of Law. Strict judicial scrutiny under the Equal Protection Clause is reserved for those cases involving explicitly guaranteed constitutional rights, and those cases that are not primarily of local concern. Public education is not a right granted to individuals by the Constitution.

Facts. This suit was initiated by Appellees Mexican-American parents whose children attend the elementary and secondary schools in the Edgewood Independent School District, an urban school district in San Antonio, Texas. They brought a class action on behalf of school children throughout the state who are members of minority groups or who are poor and reside in school districts having a low property tax base against the State Board of Education, the Commissioner of Education, the State Attorney General, and the Bexar County Board of Trustees. The Appellees argue that the State of Texas’ dual finance system in place, which provides disparate expenditures on students based on property tax revenue. The Appellees claim that this system which provided $356 per pupil in poorer areas, while providing $594 per pupil in more affluent areas violates the Equal Protection Clause of the Fourteenth Amendment. The District Court agreed, and held that the Texas school finance system was unconstituti
onal under the Equal Protection Clause of the Fourteenth Amendment.

Issue. Does the Texas system of financing public education operate to the disadvantage of some suspect class or impinge upon a fundamental right explicitly or implicitly protected by the Constitution, thereby requiring strict judicial scrutiny?

Held.
The Court holds that the Texas system does not operate to the peculiar disadvantage of any suspect class.
Public education is not a right granted to individuals in the United States Constitution, and therefore strict scrutiny under the Equal Protection Clause does not apply. The Texas system of school finance was implemented in an effort to extend public education and improve its quality.
While every reform that benefits some more than others may be criticized for what it fails to accomplish. But, it is plain that the thrust of the Texas system is affirmative and reformatory and, therefore, should be scrutinized under judicial principles sensitive to the nature of the State’s efforts and to the rights reserved to the States under the Constitution.
Under the rational basis test the Court reversed the District Court decision stating that it is an area of local concern and that the Court is unwilling to substitute its judgment for the judgment of local authorities.

Dissent.
Disagrees with the assertion that a right may be deemed fundamental for the purposes of equal protection analysis only if it is explicitly or implicitly guaranteed by the Constitution. There is no doubt that education is inextricably linked to the right to participate in the electoral process and to the rights of free speech and association guaranteed by the First Amendment. Therefore, any classification affecting education must be subjected to strict judicial scrutiny, and since even the state concedes that the statutory scheme now before the Court cannot pass constitutional muster under this stricter standard of review, it is therefore appropriate to declare this financing system invalid.
It is not enough that the Texas financing system seeks to achieve the valid, rational purpose of maximizing local initiative; but the means chosen by the state must also be rationally related to the end sought to be achieved. If the state aims at maximizing local initiative and local choice, by permitting school districts to resort to the real property tax if they choose to do so, it utterly fails in achieving its purpose in districts with property tax bases so low that there is little if any opportunity for interested parents, rich or poor to augment school district revenues. The state must be required to show that the means to effectuate its goal are rationally related to its achievement.
Disagrees with the Court’s decision that Equal Protection Clause cases fall either into the category of strict scrutiny or in the category or mere rationality. Although not all fundamental interests are constitutionality guaranteed, the determination of which interests are fundamental should be firmly rooted in the text of the Constitution. The task in every case should be to determine the extent to which constitutionally guaranteed rights are dependent on interests not mentioned in the Constitution. As the nexus between the specific constitutional guarantee and the non-constitutional interest draws closer, the non-constitutional interest becomes more fundamental and the degree of judicial scrutiny applied when the interest is infringed on a discriminatory basis must be adjusted accordingly.
Concurrence. The Equal Protection Clause confers no substantive rights and creates no substantive liberties. Rather its function is to simply measure the validity of classifications created by state laws. The basic concern is with state legislation whose purpose or effect is to create discrete and objectively identifiable classes. The Equal Protection Clause is offended only by those laws that are invidiously discriminatory – only by classifications that are wholly arbitrary or capricious.

Discussion. This case stands for the idea that strict judicial scrutiny is limited for those cases that involve explicit constitutional guarantees as written in the United States Constitution. This Court declares that since public education was not an explicitly granted right, an analysis does not rise to the level of strict scrutiny, but instead is held to a rational basis standard. It is also an example of how the Supreme Court prefers to defer cases of local rule to the locale themselves unless there is no rational basis between the regulation and the results sought. This case also shows the contention in this area because of the depth and passion of the dissents in this case.