San Antonio Independent School District v. Rodriguez, 411 U.S. 1; 93 S. Ct. 1278; 36 L. Ed. 2d 16 (1973)

Facts—Mexican American parents whose children attended elementary and secondary schools in a school district in San Antonio that had a low propertytax base challenged the Texas system of financing public education. The growing disparities between districts in population and taxable property were responsible in part for the increasingly notable differences in levels of local expenditure for education.

Question—Does the state’s system of financing public education infringe on a fundamental right explicitly or implicitly protected by the Constitution?


ReasonsJ. Powell (5–4). There is no real evidence that the financing system discriminates against any definable category of “poor” people or that it results in the absolute deprivation of education. As a result, the disadvantaged class is not susceptible to identification in traditional terms. At least where wealth is involved, the equal protection clause does not require absolute equality or precisely equal advantages. “Education, of course, is not among the rights afforded explicit protection under our federal Constitution. Nor do we find any basis for saying it is implicitly so protected.” Insofar as the system of financing schools results in disparities, it cannot be said that the arrangement is so irrational as to be individually discriminatory. There is need for reform in tax systems, but the challenged state action certainly furthers a legitimate state purpose or interest. The ultimate solutions must come from the lawmakers and from the democratic pressures of those who elect them.

J. Brennan, J. White, and J. Marshall all authored dissents claiming that the Texas scheme served no rational interest and discriminated against individuals from poorer educational districts.

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