Brief Fact Summary. In Texas, public schools were financed primarily through a system whereby property taxes were imposed by local school districts. Because property values were higher in some districts, than in others, substantial disparities across districts in per pupil spending arose. The disparities in spending among public school children triggered a Fourteenth Amendment Equal Protection challenge to the constitutionality of the system.
Synopsis of Rule of Law. A State public school taxing system that results in interdistrict spending disparities among local school districts is consistent with the Fourteenth Amendment Equal Protection Clause as long as the system satisfies the rational basis standard of review and is, thus, rationally related to a legitimate governmental interest.
Issue. Did the federal District Court, in applying strict scrutiny, review the case under the correct standard of review?
Was the funding system rationally related to a legitimate governmental interest?
Held. No and Yes. The rational basis test applies. The District Court is reversed.
Because neither a suspect classification nor a fundamental interest is implicated here, the rational basis standard of review applies. Unlike with past cases concerning laws that discriminated against the poor, this case does not involve the characteristic of poor people not being able to afford, and therefore enjoy, some important governmental benefit altogether. An interference with a fundamental right guaranteed by the Equal Protection Clause of the Fourteenth Amendment does not arise merely because some people can obtain relatively more of a desired benefit than others. Moreover, appellees have not demonstrated that the system works to the disadvantage to the poor inasmuch as the poor are often clustered around commercial areas, which produce high property tax income. Answer: It’s not mentioned precisely who the “appellees” are. Therefore, I have mad references to appellees lower case.
Because the rational basis standard of review applies, and the tax system at issue is rationally related to a legitimate governmental interest, the tax system is constitutional. Appellees’ position that the system fails rational basis review, because it allows the quality of education to fluctuate with the arbitrary drawing of boundary lines, is incorrect. Indeed, the establishment of any jurisdictional boundary will inevitably be arbitrary. Moreover, insofar as the system promotes local control and decision making in school financing affairs, the system is rationally related to a legitimate governmental interest of providing a basic education for the children of the State. As such, the program permits each locality to tailor local programs to local needs.
The majority in Rodriguez expressly noted that every claim arising under the Equal Protection Clause has implications for the relationship between national and state power under our federal system, adding that it would be difficult to imagine a case having a greater potential impact on our federal system than the one now before us, in which we are urged to abrogate systems of financing public education presently in existence in virtually every State.View Full Point of Law