San Antonio Independent School District v. Rodriguez

Last updated

San Antonio Independent School District v. Rodriguez
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued October 12, 1972
Decided March 21, 1973
Full case nameSan Antonio Independent School District, et al. v. Demetrio P. Rodriguez, et al.
Citations411 U.S. 1 ( more )
93 S. Ct. 1278; 36 L. Ed. 2d 16; 1973 U.S. LEXIS 91
Case history
PriorJudgment for plaintiffs, 337 F. Supp. 280 W.D. Tex. (1971); probable jurisdiction noted, 406 U.S. 966(1972).
SubsequentRehearing 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
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas  · William J. Brennan Jr.
Potter Stewart  · Byron White
Thurgood Marshall  · Harry Blackmun
Lewis F. Powell Jr.  · William Rehnquist
Case opinions
MajorityPowell, joined by Burger, Stewart, Blackmun, Rehnquist
ConcurrenceStewart
DissentBrennan
DissentWhite, joined by Douglas, Brennan
DissentMarshall, joined by Douglas
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 a violation of the Fourteenth Amendment's equal protection clause. [1]

Contents

The majority opinion, reversing the District Court, stated that the appellees did not sufficiently prove a textual basis, within the U.S. 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.

Background

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.

From the trial brief, Dr. Jose Cardenas, Superintendent of Schools, Edgewood Independent School District testified to the problem in his affidavit, the following information:

  1. 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.
  2. 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," which 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 that 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."

Decision

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 narrow majority in deciding that the right to be educated (as a child of school age or an uneducated adult), was neither 'explicitly or implicitly' textually found anywhere in the U.S. Constitution. It was therefore, not anywhere protected by the Constitution.

He also found that Texas had not created a suspect class related to poverty. The two findings allowed the state to continue its school financing plan as long as it was "rationally related to a legitimate state interest."

Dissent

Justices Brennan, Douglas, White, and Marshall dissented. In his dissent, Justice Marshall argued that in cases involving unenumerated rights, the Court's "task...should be to determine the extent to which constitutionally guaranteed rights are dependent on interests not mentioned in the Constitution," and "[a]s the nexus between the specific constitutional guarantee and the nonconstitutional interest draws closer, the nonconstitutional interest becomes more fundamental and the degree of judicial scrutiny applied when the interest is infringed on a discriminatory basis must be adjusted accordingly." [2]

Reaction and aftermath

In a 2015 TIME interview of over 50 legal scholars, University of California, Berkeley Law School Dean Erwin Chemerinsky and Cornell Law Professor Steven Shiffrin both named Rodriguez the "worst Supreme Court decision since 1960," with Chemerinsky noting that the decision has "played a major role in creating the separate and unequal schools that exist today." [3]

Partially in response to the Court's ruling in Rodriguez, Justice William Brennan wrote an article in the Harvard Law Review urging lawyers and litigants to turn to their State Supreme Courts — rather than the U.S. Supreme Court — to litigate their constitutional claims, as the conservative Burger Court would likely be unreceptive to claims made by racial minorities, the poor, or other "politically powerless groups whose members have historically been subjected to purposeful discrimination." [4] Since Brennan's article was published, a number of State Supreme Courts[ who? ] have held that substantially unequal public school funding violates their State Constitutions. [5]

In April 2020 a three judge panel of the United States Sixth Circuit Court of Appeals voted 2–1 in Gary B. v. Whitmer to recognize that children have a US constitutional right to basic literacy education. The panel decision distinguished San Antonio Independent School District v. Rodriguez, which did not address the fundamental right to basic education. [6] [7] [8] [9] [10] After an appeal for an en banc review, the case was settled and the panel's precedential decision vacated. [11] [12]

See also

Related Research Articles

<span class="mw-page-title-main">Thurgood Marshall</span> US Supreme Court justice from 1967 to 1991

Thoroughgood "Thurgood" Marshall was an American civil rights lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1967 until 1991. He was the Supreme Court's first African-American justice. Prior to his judicial service, he was an attorney who fought for civil rights, leading the NAACP Legal Defense and Educational Fund. Marshall was a prominent figure in the movement to end racial segregation in American public schools. He won 29 of the 32 civil rights cases he argued before the Supreme Court, culminating in the Court's landmark 1954 decision in Brown v. Board of Education, which rejected the separate but equal doctrine and held segregation in public education to be unconstitutional. President Lyndon B. Johnson appointed Marshall to the Supreme Court in 1967. A staunch liberal, he frequently dissented as the Court became increasingly conservative.

Roe v. Wade, 410 U.S. 113 (1973), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the Constitution of the United States generally protected a right to have an abortion. The decision struck down many abortion laws, and caused an ongoing abortion debate in the United States about whether, or to what extent, abortion should be legal, who should decide the legality of abortion, and what the role of moral and religious views in the political sphere should be. The decision also shaped debate concerning which methods the Supreme Court should use in constitutional adjudication.

Lawrence v. Texas, 539 U.S. 558 (2003), is a landmark decision of the U.S. Supreme Court in which the Court ruled that sanctions any form of criminal punishment to all forms of private, consensual non-procreative adult sexual activities between two individuals are unconstitutional. The Court reaffirmed the concept of a "right to privacy" that earlier cases had found the U.S. Constitution provides, even though it is not explicitly enumerated. It based its ruling on the notions of personal autonomy to define one's own relationships and of American traditions of non-interference with any or all forms of private sexual activities between consenting adults.

Elk Grove Unified School District v. Newdow, 542 U.S. 1 (2004), was a case decided by the U.S. Supreme Court. The lawsuit, originally filed as Newdow v. United States Congress, Elk Grove Unified School District, et al. in 2000, led to a 2002 ruling by the United States Court of Appeals for the Ninth Circuit that the words "under God" in the Pledge of Allegiance are an endorsement of religion and therefore violate the Establishment Clause of the First Amendment to the United States Constitution. The words had been added by a 1954 act of Congress that changed the phrase "one nation indivisible" into "one nation under God, indivisible". After an initial decision striking the congressionally added "under God", the superseding opinion on denial of rehearing en banc was more limited, holding that compelled recitation of the language by school teachers to students was invalid.

The Robin Hood Plan is a colloquialism given to a provision of Texas Senate Bill 7 , originally enacted by the U.S. state of Texas in 1993 to provide equity of school financing within all school districts in the state of Texas. The plan is now codified within the Texas Education Code as Section 49.002.

Intermediate scrutiny, in U.S. constitutional law, is the second level of deciding issues using judicial review. The other levels are typically referred to as rational basis review and strict scrutiny.

The Mexican American Legal Defense and Educational Fund (MALDEF) is a national non-profit civil rights organization formed in 1968 by Jack Greenberg to protect the rights of Latinos in the United States. Founded in San Antonio, Texas, it is currently headquartered in Los Angeles, California and maintains regional offices in Sacramento, San Antonio, Chicago, and Washington, D.C.

Goss v. Lopez, 419 U.S. 565 (1975), was a US Supreme Court case. It held that a public school must conduct a hearing before subjecting a student to suspension. Also, a suspension without a hearing violates the Due Process Clause of the Fourteenth Amendment of the US Constitution.

Vacco v. Quill, 521 U.S. 793 (1997), was a landmark decision of the Supreme Court of the United States regarding the right to die. It ruled 9–0 that a New York ban on physician-assisted suicide was constitutional, and preventing doctors from assisting their patients, even those terminally ill and/or in great pain, was a legitimate state interest that was well within the authority of the state to regulate. In brief, this decision established that, as a matter of law, there was no constitutional guarantee of a "right to die."

<span class="mw-page-title-main">Judiciary of Colombia</span>

The judiciary of Colombia is a branch of the State of Colombia that interprets and applies the laws of Colombia, to ensure equal justice under law, and to provide a mechanism for dispute resolution. The judiciary comprises a hierarchical system of courts presided over by judges, magistrates and other adjudicators.

<i>Williams v. Pryor</i>

Williams v. Pryor, 229 F.3d 1331, rehearing denied, 240 F.3d 944 was a federal lawsuit that unsuccessfully challenged an Alabama law criminalizing the sale of sex toys in the state. In 1998, a statute enacted by the legislature of the State of Alabama amended the obscenity provisions of the Alabama Code to make the distribution of certain defined sexual devices a criminal offense. Vendors and users of such devices filed a constitutional challenge to the statute in the United States District Court for the Northern District of Alabama against William H. Pryor, Jr., in his official capacity as the Attorney General of the State of Alabama. The district court declined to hold the statute violated any constitutional right but determined the statute was unconstitutional because it lacked a rational basis. The State appealed to the Eleventh Circuit Court of Appeals, which reversed the lower court ruling on October 12, 2000.

Serrano v. Priest refers to three cases regarding the financing of public schools in California that were decided by the California Supreme Court: Serrano v. Priest, 5 Cal.3d 584 (1971) ; Serrano v. Priest, 18 Cal.3d 728 (1976) ; and Serrano v. Priest, 20 Cal.3d 25 (1977).

<i>Baker v. Wade</i> U.S. court case on sodomy

Baker v. Wade 563 F.Supp 1121, rev'd 769 F.2nd 289 cert denied 478 US 1022 (1986) is a federal lawsuit challenging the legality of the sodomy law of the state of Texas. Plaintiff Donald Baker contended that the law violated his rights to privacy and equal protection. After a victory at trial, an appellate court reversed the lower court's decision and in the wake of its decision in Bowers v. Hardwick the Supreme Court of the United States refused to review it.

In law, an appeal is the process in which cases are reviewed by a higher authority, where parties request a formal change to an official decision. Appeals function both as a process for error correction as well as a process of clarifying and interpreting law. Although appellate courts have existed for thousands of years, common law countries did not incorporate an affirmative right to appeal into their jurisprudence until the 19th century.

Since the passage of the Affordable Care Act (ACA), there have been numerous actions in federal courts to challenge the constitutionality of the legislation. They include challenges by states against the ACA, reactions from legal experts with respect to its constitutionality, several federal court rulings on the ACA's constitutionality, the final ruling on the constitutionality of the legislation by the U.S. Supreme Court in National Federation of Independent Business v. Sebelius, and notable subsequent lawsuits challenging the ACA. The Supreme Court upheld ACA for a third time in a June 2021 decision.

Schuette v. BAMN, 572 U.S. 291 (2014), was a landmark decision of the Supreme Court of the United States concerning affirmative action and race- and sex-based discrimination in public university admissions. In a 6-2 decision, the Court held that the Fourteenth Amendment's Equal Protection Clause does not prevent states from enacting bans on affirmative action in education.

<i>National Coalition for Men v. Selective Service System</i> U.S. court case ruling that male-only military conscription is unconstitutional

National Coalition for Men v. Selective Service System was a court case that was first decided in the United States District Court for the Southern District of Texas on February 22, 2019, declaring that requiring men but disallowing women to register for the draft for military service in the United States was unconstitutional. The ruling did not specify which actions the government needed to take to resolve the conflict with the constitution. That ruling was reversed by the Fifth Circuit.

References

  1. ↑ San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973).
  2. ↑ 411 U.S. at 102-03 (Marshall, J., dissenting).
  3. ↑ Sachs, Andrea (October 6, 2015). "The Worst Supreme Court Decisions Since 1960". TIME. Retrieved June 23, 2021.
  4. ↑ William J. Brennan, State Constitutions and the Protection of Individual Rights, 90 Harv. L. Rev. 489, 491 (1977).
  5. ↑ "Landmark US Cases Related to Equality of Opportunity in K-12 Education". Stanford University. Retrieved August 20, 2023.
  6. ↑ Journal, A. B. A. "Students have a right to a basic minimum education, 6th Circuit rules". ABA Journal. Retrieved September 2, 2022.
  7. ↑ Testani, Rocco E. (May 21, 2020). "A Short-Lived Constitutional Right to Education". Education Next. Retrieved September 2, 2022.
  8. ↑ "Sixth Circuit Recognizes a Fundamental Right to a Basic Minimum Education - Frost Brown Todd | Full-Service Law Firm". Frost Brown Todd. May 28, 2020. Retrieved September 2, 2022.
  9. ↑ "Access to Literacy Is a Fundamental Right, Sixth Circuit Finds". www.courthousenews.com. Retrieved September 2, 2022.
  10. ↑ "Sixth Circuit Ruling on 'Fundamental Right to a Basic Minimum Education'". National Review. April 24, 2020. Retrieved September 2, 2022.
  11. ↑ Cooper, J (June 15, 2020). "Detroit literacy case ends with no legal precedent for the right to an education". World Socialist Web Site. On Wednesday, June 10, the Sixth Circuit US Court of Appeals signed an order dismissing the Gary B. v. Whitmer case, commonly known as the Detroit literacy case, legally bringing it to a conclusion. The settlement reached last month between Governor Gretchen Whitmer and the plaintiffs in the Gary B. v. Whitmer case will stand, but a legal precedent for the constitutional right to an education has been vacated.
  12. ↑ Walsh, Mark (June 12, 2020). "Federal Appeals Court Order Ends Detroit 'Right to Literacy' Case". Education Week . In a twist that appears to close the book on a nationally watched lawsuit in Detroit over a federal right to access to literacy, a federal appeals court has dismissed an appeal and recognized a settlement in the case. The June 10 order by the full U.S. Court of Appeals for the 6th Circuit, in Cincinnati, in the case known as Gary B. v. Whitmer did not disturb an earlier order that set aside an April 23 decision by a panel of the court recognizing a U.S. constitutional right to a basic minimum education guaranteeing access to literacy. Thus, the groundbreaking panel decision remains wiped off the books in the 6th Circuit, though other courts may look to the reasoning of the bold opinion that recognized the federal right of access to literacy.
  13. ↑ 179 Ariz. 233, 877 P.2d 806 (1994).
  14. ↑ 306 Kan. 1170, 402 P.3d 513 (2017).

Further reading

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.