Serrano v. Priest, 18 Cal. 3d 728 - 135 Cal. Rptr. 345, 557 P.2d 929 (1976)

Rule:

The California Constitution's equal protection provisions, while substantially the equivalent of the guarantees contained in the Fourteenth Amendment to the United States Constitution, are possessed of an independent vitality which, in a given case, may demand an analysis different from that which would obtain if only the federal standard were applicable.

Facts:

In an action challenging the constitutionality of the California public school financing system, tried on remand after the Supreme Court had reversed a prior judgment of dismissal entered upon orders sustaining general demurrers, various interested parties were allowed to intervene on both sides, but the trial court declined defendants' suggestion that the Legislature and the Governor be joined as indispensable parties. In the prior decision the Supreme Court had held that if plaintiffs' allegations were sustained on trial, the financing system must be declared invalid as in violation of state and federal constitutional provisions guaranteeing the equal protection of the laws, but during the trial itself the holding with regard to the federal provisions was undercut by the United States Supreme Court, which ruled against Texas plaintiffs in a Fourteenth Amendment attack on a generally similar system in that state. The trial court, following the law of the case, taking into consideration two new bills enacted into law during the pendency of trial proceedings, and supporting its decision by nearly 300 findings of fact, held that the California system still violated the state's, though not the federal, equal protection provisions. Indicating the nature of such violations, the court allowed six years for bringing the system into constitutional compliance, during which the existing system should continue, and retained jurisdiction so that any party might apply for appropriate relief in the event of noncompliance. Defendants' motion for new trial was denied. Certain defendants appealed. 

Issue:

Was the California public school financing system for public elementary and secondary schools violative of the California Constitution?

Answer:

Yes.

Conclusion:

On appeal by certain defendants, as supplemented by briefs of several amici curiae, the Supreme Court affirmed. Rejecting defendants' contentions that the Legislature and the Governor were indispensable parties, and noting that the criteria used by the trial court in reaching its decision were those set forth in the law of the case as declared by the Supreme Court in its prior ruling on demurrer, the court held that, despite the admitted improvements of the recent legislation, the system suffered from the same basic shortcomings that were alleged to exist in the original complaint; the system allowed the availability of educational opportunity to vary as a function of the assessed valuation (per "average daily attendance" of students) of taxable property within a given district. For purposes of determining the validity of the school financing legislation under the equal protection provisions of the state Constitution, education was a fundamental interest and discrimination in educational opportunity on the basis of district wealth involved a suspect classification; therefore, the legislation was subject to strict judicial scrutiny, and the state had the burden of showing a compelling state interest to justify such discrimination. This the state failed to do; the purported justification, namely, local control of fiscal and educational matters, was chimerical from the standpoint of districts less favored in terms of taxable wealth per pupil, and the recent legislation was insufficient to negate such inequities in the foreseeable future, primarily because of the continued availability of voted tax overrides. The court also rejected defendants' contention that other constitutional provisions, relating to school financing and educational improvement, specifically authorized the existing system, and held that in exercising its powers under such provisions the Legislature was obliged to act in a manner consistent with general constitutional limitations applicable to all legislation, including fundamental constitutional provisions guaranteeing the equal protection of the laws to all citizens of the state.