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This lawsuit was brought by members of the Edgewood Concerned Parent Association
representing their children and similarly situated students. The suit was filed on June 30, 1968
in the federal district court for the Western District of Texas. In the initial complaint, the
parents sued San Antonio ISD, Alamo Heights ISD and five other school districts, the Bexar
County School Trustees and the State of Texas contending the “Texas method of school
financing violated the equal protection clause of the Fourteenth Amendment to the U. S.
Constitution.” The lawsuit alleged that education was a fundamental right and that wealthbased discrimination in the provision of education (e.g., a fundamental right), created in the
poor, or those of lesser wealth, a constitutionally suspect class, who were to be protected from
the discrimination. Eventually, the school districts were dropped from the case leaving only the
State of Texas as the defendant. The case advanced through the courts system, providing
victory to the Edgewood parents until it reached the Supreme Court in 1972. The school
districts in the San Antonio area, and generally in Texas, had a long history of financial
inequity. Rodriguez presented evidence that school districts in the wealthy, and primarily
white, areas of town, most notably the north-side Alamo Heights Independent School District,
were able to contribute a much higher amount per child than Edgewood, which was a poor
minority area. From the trial brief, Dr. Jose Cardenas, Superintendent of Schools, Edgewood
Independent School District testified to the problem in his affidavit, the following information:
Edgewood is a poor district with a low tax base. As a result, its ad valorem tax revenue fall far
short of the monies available in other Bexar County school districts. With this inequitable
financing of its schools, Edgewood cannot hire sufficient qualified personnel, nor provide the
physical facilities, library books, equipment and supplies afforded by other Bexar County
District.
To illustrate the Edgewood residents are making a high tax effort, have burdened themselves
with one of the highest proportion of bonded indebtness in the county to pay for capital
improvements and, never, in the history of the district have they failed to approve a bond
issue.
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Did Texas public education finance system
violate the 14th Amendment’s Equal
Protection Clause by failing to distribute
funding equally among its school districts?
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It was passed by Congress on June13, 1866 and
ratified on July 9, 1868.
You are a citizen of the United States and the
State you live in, if you where either born in the
United States or become a naturalized citizen
No state can make or enforce any law which shall
abridge the privileges or immunities of citizens
of the United States
No state can deprive an person of life, liberty or
the property without due process of law
No state can deny to any person the equal
protection of the law
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The Supreme Court ruled five to four against
Rodriguez on March 21, 1973. The Court stated
that the system of school finance in the state of
Texas did not violate the federal constitution, nor
did it systematically discriminate against all poor
Texas children. Justice Powell argued that on the
issue of equity, the Equal Protection Clause did
not necessitate absolute equality in the funding
of education. In the eyes of the Court, the issue
of school funding was to be resolved by the
state. The Court refused to examine the system
of school finance with strict scrutiny due to the
fact that there is no fundamental right to
education in the Constitution.
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The Supreme Court appeared to uphold
inequity in education funding
People in poorer districts suffer most from
the decision
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Many states have since reformed their
funding systems
The Supreme Court made it more difficult to
bring cases on behalf of groups who have
been discriminated against, since this case.
In 1989 the Texas Supreme Court held that
the state needs to redo the education funding
system to have closer per-pupil expenditures
throughout the state.
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EDGEWOOD ISD V. KIRBY(1984)-The
plaintiffs contested the state's
reliance on local property taxes to
finance its system of public
education, contending that this
method was unequal because
property values varied greatly from
district to district, thus creating an
imbalance in funds available to
educate students on an equal basis
throughout the state. The court's
unanimous decision upheld the
plaintiff's claims and ordered the
state legislature to come up with a
plan by the next school year. The
final plan capped the amount of
money that districts can raise locally
through property tax, and
redistributed funds from some highwealth school districts to low-wealth
school districts.
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ROBISON V CAHIL (1973)The New
Jersey Supreme Court decision in this
case held that the school's finance
system violated the education clause
in the state's constitution, which
guaranteed an equal opportunity to
receive a thorough and efficient
system of public education. The
court held that the state was
constitutionally obliged to ensure
this opportunity, whatever the
condition of local taxing policy or
district funding decisions. Although
the concept of adequacy was an
element in this decision, it was an
undefined element
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ABBOT V. BURKE(1994)
This case extended the decision in
Robinson, ruling that all children
must have an equal opportunity that
equips children for their roles as
citizens and competitors in the
contemporary labor market. This
ruling provided a definition for
adequacy and established a rationale
for requirements that New Jersey
provide for the educational needs of
disadvantaged students by providing
additional funding using
supplemental remedial measures for
the poorer districts in the state.
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MCDUFFY V. SECRETARY OF THE
EXECUTIVE OFFICE OF
EDUCATION(1993)
Plaintiffs from 16 low-wealth
districts in Massachusetts alleged
that their schools were insufficiently
funded and that the education
provided with those resources was
inadequate by any reasonable
standard of adequacy. The court
declared that the Commonwealth was
not currently fulfilling this
constitutional duty. The state was
directed to devise a plan with
sources of funds sufficient to meet
the constitutional mandate, and the
court of entry was authorized to
determine whether, within a
reasonable time, appropriate
legislative action had been taken.
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LEANDRA V. STATE OF NORTH
CAROLINA(1997)
Alleged that the education finance
system in the state was to blame for
the physical deterioration of their
schools, a lack of basic supplies and
essential teaching equipment, and
the inability to attract high-quality
teachers. These conditions deprived
children in their districts equal or
adequate education as provided by
provisions in the state constitution.
The court held that North Carolina's
children have a right to a sound
basic education as a minimum
standard of quality and that the state
had an obligation to provide a sound
basic education applied equally to
the children in every North Carolina
school district. The decision made it
clear that districts may spend local
money to provide an education that
is even better than the required
minimum.
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CAMPAIGN FOR FISCAL EQUITY, et al
V. STATE BOF NEW YORK, et al (1993)
This was the first case to link
standards reform to adequate
funding. Plaintiffs alleged State failed
to provide students with a sound
basic education as required by the
state constitution. The aid formula
provide lower-than-average funding,
and thereby discriminated against
minority students, who are
disproportionately affected by the
funding pattern. The court found the
state financing system did not
comply with education provisions in
the state constitution.
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The Essential Programs and Services formula
that Maine uses to finance its schools does
not discriminate among school communities
in Maine, therefore it guarantees equality
based on economic diversity. The Fourteenth
Amendment is upheld in the State of Maine in
regards to Equal Protection Clause.
The EPS formula determines that adequate
funding is provided for all students in Maine
to receive a free appropriate education.