San Antonio Independent School District v. Rodriguez

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

Brief Fact Summary.

Plaintiffs challenged state funding program which allocated local property taxes for supplemental school revenue based on the amount collected in the school district.

Synopsis of Rule of Law.

A state’s financing system based on local property taxes does not violate the Equal Protection Clause of the 14th Amendment.

Facts.

Texas established a program which earmarked additional funds for schools. The formula used was designed to reflect each district’s relative taxpaying ability. Plaintiffs brought a class action suit, arguing the system disadvantaged a suspect class, i.e., poor, minority students, under the Equal Protection Clause of the 14th Amendment because certain schools lacked the vast property tax base that other districts utilized.

Issue.

Whether Texas’ financing system for schools violates the Equal Protection Clause of the 14th Amendment.

Held.

No. Texas’ financing system for schools does not violate the Equal Protection Clause of the 14th Amendment.

Dissent.

Justice Brennan

The scheme is devoid of any rational basis and violates the Equal Protection Clause. There is no doubt that education is inextricably linked tot he right to participate in the electoral process. As such, strict scrutiny should be applied.

Justice White

The means the state have chosen must also be rationally related to the end sought to be achieved and they are not. Else, equal protection analysis is no more than an empty gesture.

Justice Marshall

The task in every case should be to determine the extent to which constitutionally guaranteed rights are dependent on interests not mentioned in the Constitution. It seems to me discrimination on the basis of wealth in this case likewise calls for careful judicial scrutiny.

Concurrence.

Justice Stewart

There is hardly a law on the books that does not affect some people differently from others. The Equal Protection Clause confers no substantive rights and creates no substantive liberties. It is offended only by laws that are invidiously discriminatory.

Discussion.

Strict scrutiny does not apply because there is no fundamental right to education. Wealth discrimination also is no grounds for strict scrutiny. Having invoked no suspect class, rational basis applies.

We cannot say that such disparities are the product of a system that is so irrational as to be invidiously discriminatory. It is certainly not the product of purposeful discrimination against any group of class. On the contrary, it is rooted in decades of experience by qualified people. We are unwilling to assume for ourselves a level of wisdom superior to that of legislators, scholars, and educational authorities in the states. Judgement reversed.