San Antonio Independent School District v. Rodriguez

Citation. 411 U.S. 1, 93 S. Ct. 1278, 36 L. Ed. 2d 16, 1973 U.S. 91.

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.

Facts. In Texas, public schools were financed primarily by means of property taxes 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. For example, one district raised $26 per pupil, using a 1.05% tax rate; while another district raised as much as $333 per pupil on the basis of a mere .85% rate. The stated purpose for the system was to assure school districts of local fiscal control. At trial, a Federal District Court, applying the strict scrutiny standard of review, invalidated the school financing system on equal protection grounds.

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.

Dissent. Justice White: The Texas system cannot withstand rational basis review. It would be a more constitutionally appropriate system if it ensured minimum educational expenditures in every district through state funding, while extending an option to all local districts to increase their per pupil expenditures.
Justice Marshall: The classification at issue should have been subjected to a higher degree of scrutiny than the rational basis standard of review. Our equal protection cases cannot all fit neatly under one of two categories — rational basis or strict scrutiny. The Supreme Court of the United States should use a spectrum of standards in reviewing equal protection challenges with consideration for the societal importance of interests adversely affected and the invidiousness of classifications at issue.

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Discussion. In this case, the Supreme Court is limiting the extent to which fundamental rights can be found under the United States Constitution. The Supreme Court is saying that in order for a fundamental right to be recognizable under Fourteenth Amendment due process jurisprudence, it must be determined that such a right is explicitly or implicitly guaranteed by the Constitution. The fact that a function performed by the government is important does not establish such a function as a fundamental right. The primary focus of this case is on what standard of review should apply or why the rational basis test is the proper standard of review here.