San Antonio Independent School Dist v. Rodriguez

San Antonio Independent School Dist. v. Rodriguez, 411 US 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973)
April 23, 1973

Litigation: Challenging a Texas law relying on local property taxes, in addition to minimum education state funding, to fund K–12 education. 

Outcomes: This system of funding education through state funding plus local property tax funding continues to this day. The question whether money determines the quality of education remains disputed, except in Florida, where its high court affirmed an exhaustive lower court examination of funding and outcomes (four-week bench trial, dozens of witnesses, over 5,000 exhibits) and concluded that money is not a predictor of the quality of education (“Petitioners failed to establish any causal relationship between any alleged low student performance and a lack of resources.”) The Court also found that Florida’s school choice programs had “no negative effect on the uniformity or efficiency of the State system of public schools”). Citizens for Strong Schools, Inc. v Fla. State Bd. Of Educ., 262 So.3d 127 (Fla. 2019) 

Why it Matters: States routinely spend as much as half or more of the state’s total budget for spending taxpayer dollars on K–12 education. Devising an equitable education funding formula that is transparent, easy to understand, and that offers the greatest opportunity for children to access educational options fitting the needs of students is a daunting task. States have a state constitutional obligation to fund public schools, and this has long placed their funding priority on building a state system of government-established schools rather than prioritizing the purpose of education funding – to provide opportunity for children to learn. By prioritizing the system and those who run the system ahead of its purpose to serve children, K–12 education is providing far less opportunity than students need and deserve. 

Effects: Litigation over education funding continues to this day, sometimes resulting in court rulings that state budgets cannot support. The U.S. Supreme Court in this case offered words of wisdom that state courts should consider: “The judiciary is well advised to refrain from imposing on the States inflexible constitutional restraints that could circumscribe or handicap the continued research and experimentation so vital to finding even partial solutions to educational problems and to keeping abreast of ever-changing conditions.”