San Antonio Independent School District v. Rodriguez
| San Antonio Independent School District v. Rodriguez | |
|---|---|
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| Argued October 12, 1972 Decided March 21, 1973 |
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| Full case name | San Antonio Independent School District, et al. v. Demetrio P. Rodriguez, et al. |
| Citations | 411 U.S. 1 (more)
93 S. Ct. 1278; 36 L. Ed. 2d 16; 1973 U.S. LEXIS 91
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| Prior history | Judgment for plaintiffs, 337 F. Supp. 280 (W.D. Texas (1971) |
| Subsequent history | Rehearing denied, 411 U.S. 959 (1973) |
| Holding | |
| Reliance on property taxes to fund public schools does not violate the Equal Protection Clause even if it causes inter-district expenditure disparities. Absolute equality of education funding is not required and a state system that encourages local control over schools bears a rational relationship to a legitimate state interest. U.S. District Court for the Western District of Texas reversed. | |
| Court membership | |
| Case opinions | |
| Majority | Powell, joined by Burger, Stewart, Rehnquist, Blackmun |
| Concurrence | Stewart |
| Dissent | White, joined by Douglas, Brennan |
| Dissent | Marshall, joined by Douglas |
| Dissent | Brennan |
| Laws applied | |
| U.S. Const. amend. XIV | |
San Antonio Independent School District v. Rodriguez, 411 U.S. 1 (1973), was a case in which the Supreme Court of the United States held that San Antonio Independent School District's financing system, which was based on local property taxes, was not an unconstitutional violation of the Fourteenth Amendment's equal protection clause.
The majority opinion, reversing the District Court, stated that the appellees did not sufficiently prove a textual basis, within the US Constitution, supporting the principle that education is a fundamental right. Urging that the school financing system led to wealth-based discrimination, the plaintiffs had argued that the fundamental right to education should be applied to the States, through the Fourteenth Amendment. The Court found that there was no such fundamental right and that the unequal school financing system was not subject to strict scrutiny.
The lawsuit was brought by members of the Edgewood Concerned Parent Association representing their children and similarly situated students. The suit was filed on June 30, 1968 in the District Court for the Western District of Texas. In the initial complaint, the parents sued San Antonio ISD, Alamo Heights ISD, and five other school districts; the Bexar County School Trustees; and the State of Texas. They contended that the "Texas method of school financing violated the equal protection clause of the Fourteenth Amendment to the U. S. Constitution." The lawsuit alleged that education was a fundamental right and that wealth-based discrimination in the provision of education (such as a fundamental right), created in the poor, or those of lesser wealth, a constitutionally suspect class, who were to be protected from the discrimination.
Eventually, the school districts were dropped from the case, leaving only the State of Texas as the defendant. The case advanced through the courts system, providing victory to the Edgewood parents until it reached the Supreme Court in 1972.
The school districts in the San Antonio area, and generally in Texas, had a long history of financial inequity. Rodriguez presented evidence that school districts in the wealthy, primarily white, areas of town, most notably the north-side Alamo Heights Independent School District, were able to contribute a much higher amount per child than Edgewood, a poor, minority area.
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