1. San Antonio School Dist. v. Rodriguez, (1973)
2. Facts: Texas had a system of financing public education by allowing the local school boards the power to levy higher property taxes in their districts to pay for school upgrades. However, the state had a minimum educational standard level which applied to all schools. In urban San Antonio, there were disparities between the qualities of the school districts because the affluent children attended better school (paid for through local taxes) than the hispanic children, because the hispanic neighborhoods could not pay higher property taxes.
3. Procedural Posture: The District Court, exercising strict scrutiny, held that the Texas schme violated equal protection.
4. Issue: Whether the Texas system impinges on any fundamental right (i.e. is quality public education a fundamental right), thereby requiring strict scrutiny.
5. Holding: No.
6. Majority Reasoning: There is no reason to give quality of education the level of fundamental right for equal protection purposes. First, not all poor people live in the poorest school districts, and do not have the traditional indicia of suspectness (i.e. “immutable” characteristics - poor people can improve their financial situation). Second, the students have not been denied all public education, they is just not as much money being spent on them (and there has been no correlation shown between money and quality of education, or that the minimum standard of the state funding guarantee is insufficient to provide meaningful education). Equal protection does not require precisely equal advantages. Although education is important because it leads to informed voters and effective free speech, it is not explicitly or implicitly constitutionally protected. Lastly, the appropriate standard here is rational basis, and the Texas scheme passes.
7. Dissent Reasoning: [Marshall] Even if education is not a “fundamental” right, the court should apply higher level scrutiny than “rational basis.” Many fundamental rights are simply closely enough tied to explicitly protected rights that they must be protected to give the explicit rights any meaning. The local school district wealth bears no relation to the Texas state interest in providing educational opportunity to the students by vesting power in the local school districts to tax. Since the amount of revenue depends largely on the physical amount of property located within the district, a factor over which voters have no control, the means is not related to the ends.
