San Antonio Independent School District v. Rodriguez (1973)

Case

The 1954 landmark case Brown v. Board of Education established that education must be offered “on equal terms.” However, in 1973, the parents of children living in Edgewood Independent School District did not believe their children were receiving an equal education compared to their Alamo Heights counterparts. Texas relied on minimum state funding and local property taxes as supplemental revenue for each school district. Edgewood School District was a relatively poor district and had a higher percentage of Mexican-American and African-American students than other districts in the area. Alamo Heights School District was more affluent and mostly white. Per pupil spending in Edgewood was three-hundred fifty-six dollars while in Alamo, spending per pupil was five-hundred ninety-four dollars. This difference mirrored the difference in property tax revenues in each district. 

Rodriguez was a student in Edgewood School District whose parents challenged the Texas funding scheme, saying that students at Edgewood were underprivileged because of it. Other students and parents followed suit, filing against state and county officials. They argued that the funding plan violated the Fourteenth Amendment’s Equal Protection Clause, which provided equal protection under the law. The families hoped the Court would see wealth classifications as suspect, similarly to how they see race classifications. Suspect classes are viewed by the Court under strict scrutiny.

Decision

In a 5-4 decision, the Court denied that wealth classifications were suspect, and instead upheld Texas’ public school funding scheme. The Court decided that in order for wealth classifications to be viewed with scrutiny, they must produce an “absolute deprivation” of a “constitutionally fundamental” interest, for a “definable class of poor people.” Justice Lewis F. Powell wrote for the majority that public education was not completely denied. In addition, the Court did not find education to be a fundamental right. Although education was important, the Court did not believe it applied under the Equal Protection Clause.

The Court found that there was not a definable class of poor people. Justice Powell wrote that “the poorest families are not necessarily clustered in the poorest property districts.” In addition, the Court did not see class distinctions resulting in unequal treatment or lack of political power. Therefore, the Court concluded that the Equal Protection Clause did not apply as it “does not require absolute equality of precisely equal advantages.” The Court worried that applying protections to wealth classifications could mean all “fiscal schemes become subjects of criticism.” Texas’ public school funding scheme was upheld. 

Dissent 

Justice Byron White wrote a dissent. He argued that parents were inhibited and could not impact their children’s school district revenues to grant them a better education. Justice Thurgood Marshall also wrote a dissenting opinion, in which he stated that discrimination should be viewed through a spectrum. Marshall believed education to be a fundamental American right. Marshall noted that without an education, citizens cannot exercise their First Amendment rights and pursue interests to their greatest ability. He wrote that “education is the dominant factor affecting political consciousness and participation.” 

Impact

San Antonio Independent School District v. Rodriguez (1973), embodied the transition from the Warren Court to the Burger Court. Chief Justice Earl Warren had been one of the most liberal justices in Supreme Court history. An ideological shift in the Court was important to conservatives, so President Richard Nixon nominated the more conservative Warren Burger to take Justice Warren’s place. Under Justice Burger, the Court stepped away from establishing suspect classifications and protections under the Equal Protection Clause. Rodriguez was a major blow to Brown and made it harder to mandate equal educational opportunities. 

Surprisingly, Rodriguez led to a decrease in public school funding disparities. The majority decision did not prevent states from funding equally, so many have continued to push for a more equal funding scheme. Examining education clauses in state constitutions has been a largely successful strategy. Edgewood School District’s funding has become more level with wealthier school districts in the area. In 2004, Edgewood had slightly higher per-pupil spending than Alamo Heights School District. 

Since the case, the Latinx community in America has grown exponentially in number and diversity. As of 2013, Latinx was the largest minority in American public schools. However, equalizing educational opportunities remains an issue for the community because of high poverty rates. 

Think Further

  1. What should districts’ educational funding be based upon? 
  2. Do you agree with the three standards the majority set out for an Equal Protection claim? Why or why not?
  3. Do you agree with Justice Marshall that “education is the dominant factor affecting political consciousness and participation?” Why or why not?

Teacher Resources

Sign up for our educators newsletter to learn about new content!

Educators Newsletter

Get updated about new videos!

Newsletter

Infographic

Learn More

  1. Charles J. Ogletree Jr., The Legacy and Implications of San Antonio Independent School District v. Rodriguez, 17 Rich. J.L. & Pub. Int. 515 (2013).Available at: http://scholarship.richmond.edu/pilr/vol17/iss2/3
  2. Gillman, Howard. American Constitutionalism, Second Edition. Volume II Rights and Liberties. [Virtual Source Bookshelf].
  3. “San Antonio Independent School District v. Rodriguez.” Oyez, www.oyez.org/cases/1972/71-1332.