CASE:
SAN ANTONIO ISD v RODRIGUEZ (1973)
Introduction
In 1845, political leaders in Texas created a state constitution that called for a public education system funded primarily through local property taxes. Yet, by the 1960s, working-class schools in neighborhoods with low property values struggled to compete with schools in more affluent areas. The Edgemont School District in San Antonio, which traditionally served working class, Hispanic families, represented one such disadvantaged district.
On May 16, 1968, students at Edgewood High School staged a walkout and marched to the San Antonio Independent School District (IDS) administration building to demand better facilities and supplies. While students engaged in protests, their parents formed the Edgewood District Concerned Parents Association to lobby the Texas Board of Education to adopt a more equitable funding program for schools.
In July 1968, Demetrio Rodriguez and seven other Edgewood parents filed a class-action lawsuit in the U.S. District Court against the San Antonio ISD, Alamo Heights ISD, and other local schools. The lawsuit contended that Texas’ school financing methods violated the Equal Protection Clause of the Fourteenth Amendment. Specifically, the lawsuit asserted that wealth-based discrimination in education, if left unchecked over time, would create a permanent class of undereducated students.
On December 23, 1971, a three-judge panel ruled that the Texas school finance system discriminated based on wealth and was therefore unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. Texas officials appealed the decision to the U.S. Supreme Court. On March 21, 1973, Associate Justice Lewis Powell delivered the High Court’s 5-to-4 majority opinion. He stated that the U.S. Constitution did not specifically list education as a right, and, as a result, Texas’ method of funding school could not be considered a violation of the Fourteenth Amendment. Under such circumstances, the Texas legislature rather than the Federal Court system remained the proper public forum to address educational disparities. - Kaylea King
Constitutional Issue Raised in the Case
Was the Texas school finance system unconstitutional under the Equal Protection Clause of the Fourteenth Amendment?
Citation and Decision
San Antonio ISD v. Rodriguez, 411 U.S. 1 (1973)
No. The Supreme Court held that the Equal Protection Clause did not require absolute equality or precisely equal advantages when dealing with local schools funded by property taxes
Discussion Questions
1. Why did the students of Edgewood High School and their parents believe that they were at a disadvantage compared to other school districts?
2. Should education be considered a fundamental right, protected by the Constitution?
3. Was there a way to ensure equal funding for schools when such funding came from property taxes?
4. What other forms of funding could provide equal educational opportunities to all Texas schools?
5. If wealth-based discrimination was considered constitutional, how would this influence the definition of discrimination for future Supreme Court cases?
Links
Oyez: San Antonio ISD v. Rodriguez
Library of Congress: San Antonio ISD v. Rodriguez
NPR: For 40 Years, One Texas Family Has Fought For Equal School Funding