Plyler v. Doe

Brief Fact Summary.

Appellant challenged the practice of Texas that denies 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.

Synopsis of Rule of Law.

The Court is reluctant to impute to Congress the intention to withhold from the alien children, for so long as they are present in this country through no fault of their own, access to basic education.

Facts.

In 1975, 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 revision authorized local school districts to deny enrollment in their public schools to children not legally admitted to the country. Appellants argue that undocumented aliens, because of their immigration status, are not persons within the the jurisdiction of the State of Texas and thus have no right to the equal protection of Texas law.

Issue.

May Texas 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, there is no national policy that supports the State in denying these children an elementary education. As opposed to appellants’ argument, a concern for preservation of resources standing alone can hardly justify the classification used in allocating those resources. Also, undocumented children are basically indistinguishable from legally resident alien children. Finally, Texas did not show that the furthers some substantial state interest and thus, the Texas statute is unlawful.

Dissent.

Justice Burger

The majority states that barring undocumented children from local schools would not necessarily improve the quality of education provided in those schools. However,  the legitimacy of barring illegal aliens from programs such as Medicare or Medicaid does not depend on a showing that the barrier would improve the quality of medical care given to persons lawfully entitled to participate in such programs. Moreover, it is not irrational for a State to conclude that it does not have the same responsibility to provide benefits for persons whose very presence in the state ant his country is illegal as it does to provide for persons lawfully present.

Concurrence.

Justice Powell

The exclusion of appellee’s class of children from state-provided education is a type of punitive discrimination based on status that is impermissible under the Equal Protection Clause.

Discussion.

In determining the rationality of the Texas statute, the Court may take into account its costs to the Nation and to the innocent children who are its victims. In light of these countervailing costs, the discrimination can hardly be considered rational unless it furthers some substantial goal of the State. There is no finding in the congressional immigration scheme any statement of policy that might weigh significantly in arriving at an equal protection balance concerning the State’s authority to deprive these children of an education. The State does not claim that the conservation of the state educational resources was ever a congressional concern in restricting immigration. An illegal entrant might be granted federal permission to continue to reside in this country or even to become a citizen. In light of the discretionary federal power to grant relief from deportation, a State cannot realistically determine that any particular undocumented child will in fact be deported until after deportation proceedings have been completed. Thus, the Texas statute is held unconstitutional.