San Antonio Independent School District v. Rodriguez

PETITIONER: San Antonio Independent School District
RESPONDENT: Rodriguez
LOCATION: San Antonio Independent School District

DOCKET NO.: 71-1332
DECIDED BY: Burger Court (1972-1975)
LOWER COURT:

CITATION: 411 US 1 (1973)
ARGUED: Oct 12, 1972
DECIDED: Mar 21, 1973

ADVOCATES:
Arthur Gochman - Argued the cause for the appellees
Charles Alan Wright - Argued the cause for the appellants

Facts of the case

In addition to being funded through a state-funded program designed to establish a minimum educational threshold in every school, Texas public elementary and secondary schools rely on local property taxes for supplemental revenue. The San Antonio Independent School District (SAISD), acting on behalf of students whose families reside in poor districts, challenged this funding scheme by arguing that it underprivileged such students because their schools lacked the vast property tax base that other districts utilized. The reliance on assessable property, SAISD claimed, caused severe inter-district disparities in per-pupil expenditures.

Question

Did Texas' public education finance system violate the Fourteenth Amendment's Equal Protection Clause by failing to distribute funding equally among its school districts?

Media for San Antonio Independent School District v. Rodriguez

Audio Transcription for Oral Argument - October 12, 1972 in San Antonio Independent School District v. Rodriguez

Warren E. Burger:

We’ll hear arguments next in number 71-1332, San Antonio School District against Rodriguez.

Mr. Wright, I think you may proceed whenever you’re ready.

Charles Alan Wright:

Mr. Chief Justice and may it please the Court.

I would like to take those texts from my argument this morning, a sentence from an article that Professor Coons and his collaborators, Professors Sugarman and Clune, wrote last year.

It’s quoted-- cited on page 44 of my initial brief.

They said “of all public functions, education in its goals and methods, is least understood and most in need of local variety, experimentation, and independence.

That, I think, is wise counsel.I believe that is the argument for reversal in this case.

In our view, the Texas system of school finance, imperfect as it is, we conceded its imperfections in our brief.

The Texas system does allow through local variety, and experimentation, and independence.

Not as much as I would like it too, but that is its goal.

That is its rationale and, for that reason, there is a rational basis to it and I will undertake it of course in a moment, our view that the rational basis test is the appropriate test.

The view adopted by the District Court that there is a rigid constitutional mandate for the quality of education may not be a function of wealth except the wealth of the state as a whole, and my submission is based on educational assumptions about matters that are, today, not understood and which educators are not ready to form firm judgments and it would seriously inhibit, if it would not destroy, all together the possibilities for local variety experimentation.

Dependence of which, as Professors Coons and Elle quite properly speaks of warmly.

Proposition one, the proposition adopted by the District Court in this case, would impose a constitutional straightjacket on the public schools of 50 states.

It would mean that, hereafter and permanently, or at least until a new book is written and the constitution changes again, that all measurements in terms of school-- of education of public schools must be in terms of per capita or per pupil, student expenditures even though there may be many other things that we ought to be worrying about in an effort to cure the problems of public education.

It would not necessarily destroy all local control.

There is the variation presented by Professor Coons and his associates described as district power equalizer.

If district power equalizing is consistent with the mandate of the Court below and the Court did not undertake to speak to that question at all, it left it completely open, then it would still be possible for an individual school district to decide “we want to spend more money here than that other school district to spend it,” and there would be an elaborate system so that this could be done and its inability to do so would simply depend on the tax rate the district was willing to impose on itself.

It would not depend on the taxable property in the district.

That would leave local control still in the schools.

To that extent, it is far better than any notions of centralized state funding on a single statewide formula, but as we pointed out both in our brief and both of our briefs, and particularly in our reply brief.

It seems to us that if district power equalizing is a viable alternative, then this case has seized to be a case about education at all.

That we are no longer concerned with whether the children in the Edgewood School District have an education inferior to those in Alamo Heights because this would still be possible if the voters of Alamo Heights decided that they would assume a larger tax burden of the tax rate and the voter is Edgewood.

On the district power equalizing solution, this becomes a case for the release of the taxpayers rather than a case to help out school children.

Many of the writers who support drastic reform and who would support reform as a matter of constitutional judgment and said that the district power equalizing solution would, itself, be unconstitutional because it would make the number of dollars spent on a child depending on what his friends and neighbors think.

I must say that in view of what this--

Byron R. White:

So there would still be an equal input and there could be.

Charles Alan Wright:

There certainly could be.

In fact, the whole reason for having district power equalizing would be to unequal input possible.

Byron R. White:

But under the Texas system, it’s impossible for some districts to have a sufficient input even if they’re willing to tax themselves more.