San Antonio Independent School District v. Rodriguez
Encyclopedia
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 a school-financing system based on local property taxes was not an unconstitutional violation of the Fourteenth Amendment
's equal protection clause. The majority opinion stated that the appellees did not sufficiently prove that education is a fundamental right
, that textually existed within the US Constitution, and could thereby (through the 14th Amendment to the Constitution), be applied to the several States. The Court also found that the financing system was not subject to strict scrutiny
.
The District Court had decided that education is a fundamental right and that the financing system was subject to strict scrutiny
.
and five other school districts, the Bexar County School Trustees and the State of Texas contending 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 (e.g., 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, and 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, which was a poor minority area. From the trial brief, Dr. Jose Cardenas, Superintendent of Schools, Edgewood Independent School District testified to the problem in his affidavit, the following information:
Cardenas cites a study, "A Tale of Two Districts” that makes the following comparisons in 1967-68 between Edgewood and the North East Independent School District
:
In fact, the financial disparity between Edgewood and Alamo Heights increased in the four years it took for Rodriguez to work its way through the court system, “from a $310 total per-pupil disparity in 1968 in state and local support between the districts to a $389 disparity in 1972.”
In the Supreme Court, a new group of justices had been appointed since the filing of the case. The most significant new member was Justice Lewis Powell, who proved to be the swing vote in the Rodriguez case. Powell led the 5-4 majority in deciding that education was “neither ‘explicitly or implicitly’ protected in the Constitution.” He also found that Texas had not created a suspect class related to poverty. These two findings allowed the state to continue its school financing plan as long so it was “rationally related to a legitimate state interest.”
The Court in its analysis foreclosed for itself a quasi-constitutional amendment proposal & ratification process; in which the Court would post-hoc ratify the States’ or the US Congresses’ policy making (legislative) process as creating fundamental rights by customary use of policies that were, after a passage of time; to be interpreted as if they were texturally found in the US Constitution (based upon the states’ or the US Government’s customary implementation of the policy, e.g. public education); and then via the 14th Amendment, constitutionally interpreting such policies as being mandated upon each of the several states.
San Antonio Independent School District
San Antonio Independent School District is a school district based in Downtown San Antonio, Texas .San Antonio ISD is one of 15 school districts serving San Antonio. San Antonio ISD serves the downtown and inner city areas of San Antonio. San Antonio ISD also serves a small portion of the city of...
v. Rodriguez, 411 U.S. 1
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1973), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that a school-financing system based on local property taxes was not an unconstitutional violation of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
's equal protection clause. The majority opinion stated that the appellees did not sufficiently prove that education is a fundamental right
Right to education
The right to education is a universal entitlement to education, a right that is recognized as a human right. According to the International Covenant on Economic, Social and Cultural Rights the right to education includes the right to free, compulsory primary education for all, an obligation to...
, that textually existed within the US Constitution, and could thereby (through the 14th Amendment to the Constitution), be applied to the several States. The Court also found that the financing system was not subject to strict scrutiny
Strict scrutiny
Strict scrutiny is the most stringent standard of judicial review used by United States courts. It is part of the hierarchy of standards that courts use to weigh the government's interest against a constitutional right or principle. The lesser standards are rational basis review and exacting or...
.
The District Court had decided that education is a fundamental right and that the financing system was subject to strict scrutiny
Strict scrutiny
Strict scrutiny is the most stringent standard of judicial review used by United States courts. It is part of the hierarchy of standards that courts use to weigh the government's interest against a constitutional right or principle. The lesser standards are rational basis review and exacting or...
.
Background
This 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 federal district court for the Western District of Texas. In the initial complaint, the parents sued San Antonio ISD, Alamo Heights ISDAlamo Heights Independent School District
Alamo Heights Independent School District is a school district based in Alamo Heights, Texas . Alamo Heights ISD also serves Olmos Park, most of Terrell Hills, and a small portion of San Antonio....
and five other school districts, the Bexar County School Trustees and the State of Texas contending 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 (e.g., 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, and 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, which was a poor minority area. From the trial brief, Dr. Jose Cardenas, Superintendent of Schools, Edgewood Independent School District testified to the problem in his affidavit, the following information:
- Edgewood is a poor district with a low tax base. As a result, its ad valorem tax revenue falls far short of the monies available in other Bexar County school districts. With this inequitable financing of its schools, Edgewood cannot hire sufficient qualified personnel, nor provide the physical facilities, library books, equipment and supplies afforded by other Bexar County Districts.
- To illustrate, the Edgewood residents are making a high tax effort, have burdened themselves with one of the highest proportion of bonded indebtedness in the county to pay for capital improvements and, never, in the history of the district have they failed to approve a bond issue.
Cardenas cites a study, "A Tale of Two Districts” that makes the following comparisons in 1967-68 between Edgewood and the North East Independent School District
North East Independent School District
North East Independent School District is a school district located in Bexar County, Texas, . North East ISD serves the north central and northeast areas of Bexar County, covering approximately . North East ISD serves the cities of San Antonio, Castle Hills, Hill Country Village, Hollywood Park,...
:
- Classroom space: North East had 70.36 square feet (6.5 m²) per student; Edgewood had 50.4 square feet (4.7 m²) per student
- Library books: North East had 9.42 books per student; Edgewood had 3.9 books per student
- Teacher/Pupil Ratio: North East's ratio was 1/19; Edgewood's was 1/28
- Counselor/Pupil Ratio: North East's was 1/1,553 children; Edgewood's was 1/5,672 (the nearby Alamo Heights district had a 1/1,319 ratio)
- Dropout rate, secondary students: North East's rate was 8%; Edgewood's was 32%
In fact, the financial disparity between Edgewood and Alamo Heights increased in the four years it took for Rodriguez to work its way through the court system, “from a $310 total per-pupil disparity in 1968 in state and local support between the districts to a $389 disparity in 1972.”
In the Supreme Court, a new group of justices had been appointed since the filing of the case. The most significant new member was Justice Lewis Powell, who proved to be the swing vote in the Rodriguez case. Powell led the 5-4 majority in deciding that education was “neither ‘explicitly or implicitly’ protected in the Constitution.” He also found that Texas had not created a suspect class related to poverty. These two findings allowed the state to continue its school financing plan as long so it was “rationally related to a legitimate state interest.”
The Court in its analysis foreclosed for itself a quasi-constitutional amendment proposal & ratification process; in which the Court would post-hoc ratify the States’ or the US Congresses’ policy making (legislative) process as creating fundamental rights by customary use of policies that were, after a passage of time; to be interpreted as if they were texturally found in the US Constitution (based upon the states’ or the US Government’s customary implementation of the policy, e.g. public education); and then via the 14th Amendment, constitutionally interpreting such policies as being mandated upon each of the several states.
See also
- Abbott DistrictAbbott DistrictAbbott districts are school districts in New Jersey that are provided remedies to ensure that their students receive public education in accordance with New Jersey’s state constitution. They were created in 1985 as a result of the first ruling of Abbott v. Burke, a case filed by the Education Law...
, a legal doctrine in New JerseyNew JerseyNew Jersey is a state in the Northeastern and Middle Atlantic regions of the United States. , its population was 8,791,894. It is bordered on the north and east by the state of New York, on the southeast and south by the Atlantic Ocean, on the west by Pennsylvania and on the southwest by Delaware...
state constitutional lawNew Jersey State ConstitutionThe Constitution of the State of New Jersey is the basic governing document of the State of New Jersey. In addition to three British Royal Charters issued for East Jersey, West Jersey and united New Jersey while they were still colonies, the state has been governed by three constitutions...
resulting from a series of cases holding that the education of children in poor communities was unconstitutionally inadequate. - List of United States Supreme Court cases, volume 411