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 not the product of a system that is so irrational as to be invidiously discriminatory.

Dissent.

Justice Marshall

Any substantial degree of scrutiny of the operation of the Texas financing scheme reveals that the State has selected means wholly inappropriate to secure its purported interest in assuring its school districts local fiscal control. The wide disparities in taxable district property wealth inherent in the local property tax element of the Texas financing scheme render that scheme violative of the Equal Protection Clause. 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.

Justice White

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 parents and children in Edgewood, and in like districts, suffer from an invidious discrimination violative of the Equal Protection Clause.

Discussion.

No distinguishing characteristics of wealth classifications can be found here. First, in support of their charge that the system discriminates against the poor, appellees have made no effort to demonstrate that it operates to the peculiar disadvantage of any class fairly definable as indigent, or as composed of persons whose incomes are beneath any designated poverty level. Indeed, there is reason to believe that the poorest families are not necessarily clustered in the poorest property districts. Second, lack of personal resources has not occasioned an absolute deprivation of the desired benefit. Apart from the unsettled and disputed question whether the quality of education may be determined by the amount of money expended for it, a sufficient answer to appellees’ argument is that, at least where wealth is involved, the Equal Protection Clause does not require absolute equality or precisely equal advantages. The people of Texas may be justified in believing that other systems of school financing, which place more of the financial responsibility in the hands of the State, will result in a comparable lessening of desired local autonomy.