San Antonio Indep. Sch. Dist. v. Rodriguez

411 U.S. 1, 93 S. Ct. 1278 (1973)



The traditional indicia of suspectness include whether a class is saddled with disabilities, or subjected to a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process.


In a suit by plaintiff parents on behalf of school children throughout Texas who were members of minority groups, or who were poor and resided in school districts having a low property tax base, the lower court held that the Texas school finance system was unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. The lower court based its decision on the substantial inter-district disparities in school expenditures largely attributable to differences in the amounts of money collected through local property taxation. On appeal, the Court reversed the decision of the lower court,


Does the system of financing public education based on property taxes that results in significant disparities in funding among school districts, violate the Fourteenth Amendment rights of children attending schools in less-affluent districts?




The Supreme Court held that where wealth was involved, the Equal Protection Clause did not require absolute equality or precisely equal advantages. The Court found that the Texas system did not operate to the peculiar disadvantage of any suspect class. The Court rejected the lower court's finding that education was a fundamental right or liberty. The strict scrutiny test was inappropriate and applied a standard of review that required only that the State's system be shown to bear some rational relationship to legitimate State purposes. The Texas plan satisfied the standard, and thus, the Court reversed.

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