Selected Moments of the 20th Century

A work in progress edited by Daniel Schugurensky
Department of Adult Education, Community Development and Counselling Psychology,
The Ontario Institute for Studies in Education of the University of Toronto (OISE/UT)

1973

San Antonio School District v. Rodriguez

The United States Supreme Court, in 1973, put an end to attempts to equalize the public education system through the federal courts (Kozol 1991). In the case of San Antonio School District v. Rodriguez, the U.S. Supreme Court overruled the judgment of a district court in Texas that had found the state's system of financing its schools unconstitutional.

The Rodriguez case alleged that the Texas financing scheme taxed residents of the poor Edgewood district at a higher rate than residents of the wealthy Alamo Heights district. Even further, Edgewood district residents were unable to raise local revenues for its schools. Thus, the state provided the Edgewood district with the minimum amount of funding, while the Alamo Heights district was given the maximum amount of funding because it raised local revenues. In essence, the poor districts were being taxed more, but not given adequate state funding because these districts could not raise local revenue (Neville 1986).

As a result, a class-action suit was filed on behalf of Demetrio Rodriguez and other parents of the Edgewood district. The federal district court found Texas' financing scheme in violation of the equal protection clause of the U.S. Constitution. On appeal, the U.S. Supreme Court ruled that a state does not have a constitutional duty to ensure that poor school districts get the same funding as wealthy districts.

Arguing on behalf of Demetrio Rodriguez and parents of the Edgewood District, the Mexican American Legal and Defense Fund (MALDEF) made a concerted effort before the Supreme Court to challenge the public school financing practices in Texas. MALDEF was hopeful that the Court would follow one of the criterion it developed: 1.) wealth should be considered a suspect classification; 2.) Texas' school finance law should be considered a racial classification; 3.) education should be considered a "fundamental right"; and 4.) Texas' school finance law has no rational basis (Buzan 1992).

MALDEF's reasoning in developing the above criterion is that when laws are based on a suspect classification, such as race or wealth, the effect of these laws may raise equal protection claims. In Rodriguez, the Court said that wealth would not be considered a suspect classification. Therefore, it was up to MALDEF to prove that the Texas finance law intended to discriminate against the residents of the Edgewood District. If the Supreme Court would have considered wealth a suspect classification or the Texas finance law a racial classification, the burden of proof would have shifted to the state to show that its law served an important governmental objective (Peltason 1991).

Given previous rulings dealing with issues discussed in the Rodriguez case, it is important to note that the Supreme Court has not always followed a particular judicial precedent--such as wealth as a suspect classification or unequal educational facilities as a racial classification. Although wealth, or lack of it, has not ordinarily been considered a suspect classification, the Supreme Court in Shapiro v. Thompson (1969) viewed poverty as a suspect classification. In Shapiro, the Supreme Court overturned an Illinois law stating that a person must live a certain number of years in the state to receive welfare (Buzan 1992).

The inequality of educational facilities was also an issue that went before the Supreme Court. In Sweatt v. Painter (1951), the Court ruled that because black law schools were not equal to white law schools, black students must be able to attend the white law schools. In his dissent of the Rodriguez case, Justice Thurgood Marshall referred to Sweatt and stated that just as the Court had struck down a practice that caused a differential impact on a certain group because of unequal educational facilities, the same should be applied to Rodriguez since the same holds true for students of the Edgewood District (Gunther 1991).

Since the Rodriguez case in 1973, the Supreme Court has made it more difficult to litigate on behalf of groups that have been discriminated against in one form or another. One year following Rodriguez, the Supreme Court ruled in Milliken v. Bradley that bussing could not be forced across school district lines without proof of de jure segregation in all districts. Washington v. Davis (1976) involved the validity of a qualifying exam for police applicants in the District of Columbia. Many minority applicants were rejected on the basis of the written exam and claimed the test was racially discriminatory in effect. However, the Supreme Court ruled that the plaintiff (the minority applicants) must prove intent to discriminate by the defendant (the police department) (Buzan 1992). Ultimately, the Supreme Court has made it more difficult to remedy equity in schools and in society since Rodriguez.

For More Information:
San Antonio School District v. Rodriguez

Sources:

Buzan, B. Politics & Society 129B: Civil Rights & Civil Liberties, Fall 1992.

Gunther,G. (1991). Constitutional Law. Westbury, N.Y.: Foundation Press.

Kozol, J. (1991). Savage inequalities. Harper Perennial.

Neville, J. (1986). Constitutional Law. Harcourt Brace Jovanovich Legal & Professional Publications, Inc.

Peltason, J. (1991). Understanding the Constitution. Harcourt Brace Jovanovich, Publishers.

Prepared by Roxanne Elizondo (UCLA)

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