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.

In light of the countervailing costs, the discrimination contained in the Texas statute can hardly be considered rational unless it furthers some substantial goal of the State.

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, Texas may not 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, because undocumented aliens cannot be treated as a suspect class since their presence in this country in violation of federal law is not a constitutional irrelevancy. Nor is education a fundamental right; a state need not justify by compelling necessity every variation in the manner in which education is provided to its population.

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 appellee children are innocent in this case. A legislative classification that threatens the creation of an underclass of future citizens and residents cannot be reconciled with one of the fundamental purposes of the Fourteenth Amendment. The State’s denial of education to these children bears no substantial relation to any substantial state interest.

Justice Blackmun

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 those purposes of the Equal Protection Clause. Children denied an education are placed at a permanent and insurmountable competitive disadvantage, for an uneducated child is denied even the opportunity to achieve. And when those children are members of an identifiable group, that group will have been converted into a discrete underclass. Other benefits provided by the State, such as housing and public assistance, are of course important. But classifications involving the complete denial of education are in a sense unique, for they strike at the heart of equal protection values by involving the State in the creation of permanent class distinctions.

Justice Marshall

A class-based denial of public education is utterly incompatible with the Equal Protection Clause.

Discussion.

There is no evidence suggesting that illegal entrants impose any significant burden on the State’s economy. To the contrary, the available evidence suggests that illegal aliens underutilize public services, while contributing their labor to the local economy and tax money to the state fisc. The record also does not support the claim that exclusion of undocumented children is likely to improve the overall quality of education in the State. Even if improvement in the quality of education were a likely result of barring some number of children from the schools of the State, the State must support its selection of this group as the appropriate target for exclusion. Finally, it is clear that whatever savings might be achieved by denying these children an education, they are wholly insubstantial in light of the costs involved to these children, the State, and the Nation.