San Antonio Independent School District v. Rodriguez
411 U.S. 1 (1973)

  • Texas funded their public schools with property taxes. They gave each school funding based on the amount of property taxes collected in that school district.
    • This meant that schools in poor communities with low property values and a corresponding low property tax bas received less money per student than schools in rich communities with high property taxes.
  • A group of parents in a poor community sued, claiming that the apportionment was a violation of the Equal Protection Clause of the 14th Amendment because it unconstitutionally discriminated on the basis of wealth.
  • The Trial Court found the law to be unconstitutional. Texas appealed.
    • The Trial Court found that education was a fundamental right, and therefore the Texas law should be subject to strict scrutiny.
  • The US Supreme Court found the Texas apportionment to be constitutional.
    • The US Supreme Court found that there is no fundamental right to education, nor were poor people a suspect class.
      • Therefore, the Texas law only had to pass rational basis review.
    • The Court found that Texas’ plan was rationally related to a legitimate State interest, and was therefore constitutional.
      • The State interest was the desire to have local control over schools.