Cecilie Richmond and Cesar Fuentes – Case Brief
October 4th, 2010
Title and Citation:
San Antonio Independent School District v. Rodriguez
Supreme Court of the US, 1973.
411 U.S. 1, Ct. 1278, rehearing denied
411 U.S. 959, 93 S. Ct. 1919 (1973).
Facts of the Case:
Mexican-American parents of the urban Texas school district,
Edgewood Independent School District, became irate towards the disparity
of funding for their students and schools compared to nearby North East
Independent school district and its schools. On May 16th, 1968, 400 students
at Edgewood High School in San Antonio held a walk-out and
demonstration, and marched to the district administration office to state the
findings of a study cited by the district’s superintendent. This study, “A
Tale of Two Districts” made the following comparisons between Edgewood
and the North East district:
 Classroom space: North East had 70.36 square feet per student;
Edgewood had 50.4 square feet per student.
 Library books: N.E. had 9.42 books per student; Edgewood had 3.9
books per student.
 Teacher/ Pupil Ratio: N.E. ratio was 1/19; Edgewood’s was 1/28.
 Counselor/Pupil Ratio: N.E. was 1/1,552 children; Edgewood’s
was 1/5,672.
 Dropout rate: N.E. rate was 8%; Edgewood 32%
The superintendent, Dr. Jose Cardenas, explained that these disparities were
attributed to the fact that Edgewood is a poor district in a low tax base –
its ad valorem tax revenue is, consequently drastically less than other
districts in the Bexar county region of Texas. Cardenas further explained
that this low tax base is not the fault of the resident’s voting decisions with
their history of voting to pay higher tax rates to fund bond issues. The
problem is that their financing system is based on property taxes. Of course,
the property value of this poor district would receive less property value tax
support for its schools with lower income housing.
The group of Edgewood parents first went to the Mexican American
Legal Defense and Educational Fund to seek support, without success. In
July of 1968, Demetrio Rodriguez and 7 other parents filed for all Texas
schoolchildren of low socioeconomic standing and /or those who lived in
low property-tax bases. Their complaint was that their district had high tax
rates compared to other areas in the country, although there was still only
$37 per student compared to the $413 per student raised in Alamo Heights
(the wealthiest district in the state).
In January of 1969, a 3-judge federal district court was impaneled
(required a jury to make a decision) because Rodriguez had challenged a
state law on federal grounds. They had argued to big claims that no federal
court accepted; 1. the Fourteenth Amendment to the Constitution made
education a “fundamental right,” 2. poor and Mexican-American families
were treated as a “suspect class” (A presumptively unconstitutional
distinction made between individuals on the basis of race, national
origin, alienage, or religious affiliation, in a statute, ordinance,
regulation, or policy - http://legaldictionary.thefreedictionary.com/Suspect+class).
In December of 1971, the 3-judge court ruled on Rodriguez stating
that Texas school-finance system was unconstitutional under the “equal
protection” clause of the Fourteenth Amendment. However, the state
appealed (didn’t like) this decision and it went on to the U.S. Supreme Court
as San Antonio ISD v. Rodriguez. It was noted that the attorney’s general of
25 states agreed with Rodriguez.
On March 21, 1973, the S.C. ruled five to four against Rodriguez due
to the fact that the school finance system did not violate the federal
constitution and that the issue should be resolved by the state. It was also
decided that the state would not need to subsidize (provide additional
support) to poorer school district.
The vote:
The Supreme Court ruled five to four against Rodriguez. The author of the
majority opinion was J. Powell, joined by Burger, Steward, Rehnquist,
Blackmun.
The law and/or Constitutional Provisions at issue:
The Fourteenth Amendment to the Constitution is debated in this case to
mean that education is a “fundamental right.”
Poor and Mexican-American families were treated as a “suspect class.”
The Legal Questions / Court Opinions with answers and reasons
1. Is Texas discriminating against poor persons whose income falls
below a certain level? Texas was not discriminating due to the fact
that there was more of a concern for the minimum requirements
2.
3.
4.
5.
6.
versus the disparity between the 2 groups. Minimum requirements
were met.
Is Texas discriminating against those who are relatively poorer than
others? According to the court, they are not because everyone is
getting what is constitutionally required.
Is Texas discriminating against all those who happen to live in poorer
school districts? Cesar and I believe there is discrimination here –
although the court’s judgment was equal and fair because bare
minimums were met.
Does the Texas system violate the Equal Protection Clause of the
Fourteenth Amendment? No, we hold that the Texas plan abundantly
satisfies the standard. There is no showing that the Texas system fails
to provide the basic minimal skills necessary for that purpose.
Isn’t education explicitly protected in the constitution?
Had Texas created a “suspect class” related to poverty with their
presentation of the disparity between different socioeconomic classes
of school districts?
Concurring / Dissenting Opinions:
Brennan: Dissenting because he felt that even though education is not
explicitly afforded under the constitution, it really should be. He argues that
under closer review the Texas financial scheme is constitutionally invalid.
MR. JUSTICE WHITE, with whom MR. JUSTICE DOUGLAS and MR.
JUSTICE BRENNAN join, dissenting because the constitution should
provide rather than a minimum, an equitable educational opportunity.
MR. JUSTICE STEWART, concurring because he is following the word of
the pre-established law. Unlike voting laws that were more closely defined
by the 15th and the 19th amendment, there is no precursor to constitutionally
validate a dissention from the established norm.
Evaluation of the case:
The importance of the decision made from this case is that the constitution
does not explicitly ensure equal education for all students. This case led to
the 1984 Edgewood v Kirby hearing that successfully continued the battle
for educational equity. If this case had been the “final word” on equal
education opportunities, the disparity between the socioeconomic classes
might still prevail today!