San Antonio Independent School District v. Rodriguez

Brief Fact Summary.

The 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, challenged the Texas system of financing public education.

Synopsis of Rule of Law.

The application of the traditional standard of review requires only that the State’s system be shown to bear some rational relationship to legitimate state purposes.

Facts.

The school district in which appellees reside, the Edgewood Independent School District, is one of the seven public school districts in the metropolitan area. The district is situated in the core-city sector of San Antonio in a residential neighborhood that has little commercial or industrial property. The residents are predominantly of Mexican-American descent. The average assessed property value per pupil is the lowest. At a tax rate of $1.05 per $100 of assessed property, the district contributed $26 to the education of each child. Alamo Heights is one of the most affluent school in San Antonio. Its six schools, housing 5000 students, are situated in a residential community quite unlike the Edgewood District. The school population is predominantly Anglo having only 18% Mexican-Americans. The local tax rate of $.85 per $100 valuation yielded $333 per pupil over its contribution to the Foundation program.

Issue.

Does the Texas system of school financing that results in unequal expenditures between children who happen to reside in different districts violate the Constitution?

Held.

No, the Texas system does not operate to the peculiar disadvantage of any suspect class. To the extent that the Texas system of school financing results in unequal expenditures between children who happen to reside in different districts, such disparities are the product of a system that is so irrational as to be invidiously discriminatory.

Dissent.

Justice Marshall

As the nexus between the specific constitutional guarantee and the nonconstitutional interest draw closer, the nonconstitutional interest become more fundamental and the degree of judicial scrutiny applied when the interest is infringed on a discriminatory basis must be adjusted accordingly. The majority’s approach seems to be the guarantees of our Constitution with oppression of and discrimination against discrete, powerless minorities which underlie that document.

Discussion.

In support of their charge that the system discriminates against the poor, there is reason to believe that the poorest families are not necessarily clustered in the poorest property districts. Also, lack of personal resources has not occasioned an absolute deprivation of the desired benefit. Apart from the disputed question whether the quality of education may be determined by the amount of money expended for it, the Equal Protection Clause odes not require absolute equality or precisely equal advantages. The system of alleged discrimination and the class it defines have none of the traditional indicia of suspectness: the class is not saddled with such 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.