The u.s. supreme courts ruling in the san antonio v. rodriguez (1973) case was that _____

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Facts of San Antonio Independent School District v Rodriguez
Supreme Court Decision in San Antonio Independent School District v Rodriguez
The Dissent in San Antonio Independent School District v Rodriguez

In San Antonio Independent School District v Rodriguez, 411 U.S. 1 (1973), the U.S. Supreme Court held that the right to education was not a fundamental right under the U.S. Constitution that triggered strict scrutiny. Accordingly, the Court held that San Antonio Independent School District’s school financing system did not run afoul of the Fourteenth Amendment’s Equal Protection Clause.

Facts of San Antonio Independent School District v Rodriguez

In the 1970s, the financing of public elementary and secondary schools in Texas was a product of state and local participation. Almost half of the revenues were derived from a largely state-funded program designed to provide a basic minimum educational offering in every school. Each district supplemented state aid through an ad valorem tax on property within its jurisdiction.

The class-action suit was brought on behalf of school children from poor families who resided in school districts with a low property tax base, making the claim that the Texas system’s reliance on local property taxation favored the more affluent. Accordingly, the suit further alleged that the financing system violated equal protection requirements because of substantial inter-district disparities in per-pupil expenditures resulting primarily from differences in the value of assessable property among the districts.

The District Court, finding that wealth is a “suspect” classification and that education is a “fundamental” right, concluded that the system could be upheld only upon a showing, which the school district failed to make, that there was a compelling state interest for the system. The court also concluded that appellants failed even to demonstrate a reasonable or rational basis for the State’s system.

Supreme Court Decision in San Antonio Independent School District v Rodriguez

By a vote of 5-4, the Court reversed. “This is not a proper case in which to examine a State’s laws under standards of strict judicial scrutiny, since that test is reserved for cases involving laws that operate to the disadvantage of suspect classes or interfere with the exercise of fundamental rights and liberties explicitly or implicitly protected by the Constitution,” Justice Lewis F. Powell, Jr. wrote on behalf of the majority.

Applying intermediate scrutiny, the majority concluded that the Texas system did not violate the Equal Protection Clause of the Fourteenth Amendment. “In sum, to the extent that the Texas system of school financing results in unequal expenditures between children who happen to reside in different districts, we cannot say that such disparities are the product of a system that is so irrational as to be invidiously discriminatory,” the majority held.

According to the Court, the Texas system did not disadvantage any suspect class. “It has not been shown to discriminate against any definable class of ‘poor’ people or to occasion discriminations depending on the relative wealth of the families in any district,” Justice Powell wrote. “And, insofar as the financing system disadvantages those who, disregarding their individual income characteristics, reside in comparatively poor school districts, the resulting class cannot be said to be suspect.”

More importantly, the majority further found that Texas school financing system did not impermissibly interfere with the exercise of a “fundamental” right or liberty. Justice Powell wrote:

Though education is one of the most important services performed by the State, it is not within the limited category of rights recognized by this Court as guaranteed by the Constitution. Even if some identifiable quantum of education is arguably entitled to constitutional protection to make meaningful the exercise of other constitutional rights, here there is no showing that the Texas system fails to provide the basic minimal skills necessary for that purpose.

The Dissent in San Antonio Independent School District v Rodriguez

Justice Thurgood Marshall authored a dissenting opinion. He wrote: “The majority’s holding can only be seen as a retreat from our historic commitment to equality of educational opportunity. … In my judgment, the right of every American to an equal start in life, so far as the provision of a state service as important as education is concerned, is far too vital to permit state discrimination…”

Citation411 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.

Points of Law - Legal Principles in this Case for Law Students.

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

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.

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.