San Antonio Independent School District v. Rodriguez

Fact Box

San Antonio Independent School District v. Rodriguez
Appellee: Rodriguez
Appellant: San Antonio Independent School Dis.

Decision: 5 votes for San Antonio Independent School District, 4 against
Facts of the Case 

In addition to being funded through a state-funded program designed to establish a minimum educational threshold in every school, Texas public elementary and secondary schools rely on local property taxes for supplemental revenue. The San Antonio Independent School District (SAISD), acting on behalf of students whose families reside in poor districts, challenged this funding scheme by arguing that it underprivileged such students because their schools lacked the vast property tax base that other districts utilized. The reliance on assessable property, SAISD claimed, caused severe inter-district disparities in per-pupil expenditures.


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

Decision: 5 votes for San Antonio Independent School Dis., 4 vote(s) against
Legal provision: Equal Protection

No. The Court refused to examine the system with strict scrutiny since there is no fundamental right to education in the Constitution and since the system did not systematically discriminate against all poor people in Texas. Given the similarities between Texas' system and those in other states, it was clear to the Court that the funding scheme was not "so irrational as to be invidiously discriminatory." Justice Powell argued that on the question of wealth and education, "the Equal Protection Clause does not require absolute equality or precisely equal advantages."