Litigation

San Antonio Independent School Dist. v. Rodriguez 

  • Plantiff:
    San Antonio Independent School Dist
  • Defendant:
    Rodriguez
  • Full Case Name:
    San Antonio Independent School Dist. v. Rodriguez, 411 US 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973)
  • As Of:
    April 23, 1973

Summary Question

Does Texas' public education finance system violate the Fourteenth Amendment's Equal Protection Clause by failing to distribute funding equally among its school districts?

Summary Answer

NO. The Court held that there is no constitutional right to education found in the federal constitution. “It is not the province of this Court to create substantive constitutional rights in the name of guaranteeing equal protection of the laws.” Furthermore, the Court held that the Equal Protection Clause of the 14th Amendment does not require absolute equality. Whereas it was argued that children living in districts with lower property wealth received a “poorer quality education,” the Court said the question whether money determines the quality of education was an “unsettled and disputed question.” The Court held that the Equal Protection Clause does not require “absolute equality or precisely equal advantages.” Also, since many other states had adopted similar funding methods, mixing state and local funds to pay for education was not irrational. The state’s guarantee to provide an adequate education, fulfilled by its minimum base funding, was enough to pass constitutional scrutiny.

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.”