San Antonio Independent School District v. Rodriguez (1973)

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.

Citation: 411 U.S. 1 (1973)
Date decided: Mar 21, 1973
Longer case name: San Antonio Independent School District et al. v. Rodriguez et al.
Law type: Civil
Jurisdiction level:Federal
State of origin: Texas
Topic(s):Education, Equal protection, Fundamental rights, and School finance
Lists:Important cases
Attorneys:Arthur Gochman argued the cause for appellees. With him on the brief was Mario Obledo (Mexican American Legal Defense and Educational Fund, MALDEF).
Others involved:Briefs of amici curiae urging affirmance were filed by David Bonderman and Peter Van N. Lockwood for Wendell Anderson, Governor of Minnesota, et al.; by Robert R. Coffman for Wilson Riles, Superintendent of Public Instruction of California, et al.; by Roderick M. Hills for Houston I. Flournoy, Controller of California; by Ramsey Clark, John Silard, David C. Long, George L. Russell, Jr., Harold J. Ruvoldt, Jr., J. Albert Woll, Thomas E. Harris, John Ligtenberg, A. L. Zwerdling, and Stephen I. Schlossberg for the Mayor and City Council of Baltimore et al.; by George H. Spencer for San Antonio Independent School District; by Norman Dorsen, Marvin M. Karpatkin, Melvin L. Wulf, Paul S. Berger, Joseph B. [411 U.S. 1, 5] Robison, Arnold Forster, and Stanley P. Hebert for the American Civil Liberties Union et al.; by Jack Greenberg, James M. Nabrit III, Norman J. Chachkin, and Abraham Sofaer for the NAACP Legal Defense and Educational Fund, Inc.; by Stephen J. Pollak, Ralph J. Moore, Jr., Richard M. Sharp, and David Rubin for the National Education Assn. et al.; and by John E. Coons for John Serrano, Jr., et al. Briefs of amici curiae were filed by Lawrence E. Walsh, Victor W. Bouldin, Richard B. Smith, and Guy M. Struve for the Republic National Bank of Dallas et al., and by Joseph R. Cortese, Joseph Guandolo, Bryce Huguenin, Manly W. Mumford, Joseph H. Johnson, Jr., Joseph Rudd, Fred H. Rosenfeld, Herschel H. Friday, George Herrington, Harry T. Ice, Cornelius W. Grafton, Fred G. Benton, Jr., Eugene E. Huppenbauer, Jr., Harold B. Judell, Robert B. Fizzell, John B. Dawson, George J. Fagin, Howard A. Rankin, Huger Sinkler, Robert W. Spence, Hobby H. McCall, James R. Ellis, and William J. Kiernan, Jr., Bond Counsel.
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Case Importance

From Wikipedia: “In a TIME interview of over 50 legal scholars, California 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.’ 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 have held that substantially unequal public school funding violates their State Constitutions.”

Case Details

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)


The financing of public elementary and secondary schools in Texas is a product of state and local participation. Almost half of the revenues are derived from a largely state-funded program designed to provide a basic minimum educational offering in every school. Each district supplements state aid through an ad valorem tax on property within its jurisdiction. Appellees brought this class action on behalf of schoolchildren said to be members of poor families who reside in school districts having a low property tax base, making the claim that the Texas system’s reliance on local property taxation favors the more affluent and violates equal protection requirements because of substantial interdistrict 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 appellants failed to make, that there was a compelling state interest for the system. The court also concluded that appellants failed even to [411 U.S. 1, 2] demonstrate a reasonable or rational basis for the State’s system. Held:

1. 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. Pp. 18-44.

(a) The Texas system does 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. 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. Pp. 18-28.

(b) Nor does the Texas school-financing system impermissibly interfere with the exercise of a “fundamental” right or liberty. 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. Pp. 29-39.

(c) Moreover, this is an inappropriate case in which to invoke strict scrutiny since it involves the most delicate and difficult questions of local taxation, fiscal planning, educational policy, and federalism, considerations counseling a more restrained form of review. Pp. 40-44.

2. The Texas system does not violate the Equal Protection Clause of the Fourteenth Amendment. Though concededly imperfect, the system bears a rational relationship to a legitimate state purpose. While assuring a basic education for every child in the State, it permits and encourages participation in and significant control of each district’s schools at the local level. Pp. 44-53.

337 F. Supp. 280, reversed.

Last modified: 2022-12-27 12:57
Case internal grade: A | Case internal status: OK |
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