Law School Case Brief
Kadrmas v. Dickinson Pub. Sch. - 487 U.S. 450, 108 S. Ct. 2481 (1988)
Unless a statute provokes "strict judicial scrutiny" because it interferes with a "fundamental right" or discriminates against a "suspect class," it will ordinarily survive an equal protection attack so long as the challenged classification is rationally related to a legitimate governmental purpose. Where a statute is principally an economic statute and rationally related to a legitimate objective and is not arbitrary or irrational, the statute will be upheld.
Since 1947, the North Dakota state legislature has authorized and encouraged thinly populated school districts to consolidate or reorganize into larger, more efficient districts. Reorganization plans are required by law to include provisions for school transportation and such provisions can be changed only with the approval of the voters. A 1979 statute, N.D. Cent. Code, ch. 15-27.3, provided that non-reorganized school districts may charge a fee for transporting students to school. In the non-reorganized school district of Dickinson, North Dakota, a low-income family that included a schoolchild and two preschool children refused to sign a contract obligating them to pay the $ 97 school bus fee for the 1985 school year, the family having fallen behind on previous school bus bills. The family arranged to transport the schoolchild privately at a much greater expense, until the mother signed bus service contracts for part of the 1986 school year and for the 1987 school year and made partial payments of those fees. Meanwhile, in September 1985, the mother and the schoolchild filed an action in a North Dakota state District Court seeking to enjoin the Dickinson school district and various school officials from collecting any fee for bus service. The action was dismissed on the merits, and on appeal, the decision was affirmed by the Supreme Court of North Dakota. It held that the school bus fee statute did not violate the mother's and child's rights to equal protection under the Federal Constitution's Fourteenth Amendment.
Was the state statute allowing local school boards to assess a transportation fee for pupils unconstitutional as a violation of equal protection?
The U.S. Supreme Court determined that the North Dakota statute at issue was principally an economic statute and would be upheld because it rationally related to a legitimate government objective and was not arbitrary or irrational. The Court affirmed the lower court's judgment, finding that the local school board was not required to provide the service and charging the fee did not deprive the students of their right to an education. Affirming the judgment, the court held that the challenged statute--which allowed local school boards the option of charging patrons a user fee for school bus service--discriminated against no suspect class and interfered with no fundamental right; thus, the statute did not violate the Equal Protection Clause of the Fourteenth Amendment.
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