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A Latinx Resource Guide: Civil Rights Cases and Events in the United States

1973: San Antonio ISD v. Rodriguez

"In sum, to the extent that the Texas system of school financing results in unequal expenditures between children who happen to reside in different districts, we cannot say that such disparities are the product of a system that is so irrational as to be invidiously discriminatory."

—Justice Lewis Powell

Alan Lomax, photographer. Mexican girls, San Antonio, Texas. 1934. Library of Congress Prints and Photographs Division.

The 5-4 United States Supreme Court decision in San Antonio ISD v. Rodriguez (1973) ruled no constitutional right to an equal education, held no violation of rights in Texas’ school system, and reserved jurisdiction and management of Texas’ public school finance system to the state.

On July 10, 1968, Demitrio Rodriguez and a group of San Antonio parents filed a class action lawsuit on behalf of minority students from low-income school districts. Their attorney, Arthur Gochman, denounced Texas’ inequitable public school finance system, and showed that the Edgewood district, with a predominantly Mexican-American population, and one of the highest tax rates in the Bexar Country, received $37 per pupil, while the more affluent and Anglo students in Alamo Heights got $413 per pupil.

A three-judge federal district court ruled in favor of the plaintiffs finding Texas’ public school finance system discriminatory based on wealth. They argued this inequity was unconstitutional under the Equal Protection Clause of the 14th Amendment. Additionally, they ruled that education is a “fundamental” right. The State of Texas appealed the case to the U.S. Supreme Court.

On March 21, 1973, Justice Powell delivered the Supreme Court decision stating that the “Equal Protection Clause does not require absolute equality of precisely equal advantages”. Furthermore, the court ruled that the State of Texas had not “deprived” any student access to education, an entity not protected by the 14th Amendment. They also found no occurring discrimination on the basis of wealth, and retained management of school funding methods to the state and its representatives.

In 1984, Rodriguez v. San Antonio ISD (1973) led to another U.S. Supreme Court landmark case: Edgewood Independent School District v. Kirby (1992), where Demitrio Rodriguez, the Mexican American Legal Defense and Educational Fund (MALDEF), and parent associations challenged Texas' school funding system again. In 1992, the Supreme Court ruled in favor of the plaintiffs and held Texas’ school financing system unconstitutional.

Timeline

1845 Texas’ Constitution provides free access to public education using property taxes as school district funding
May 16, 1968 400 students walkout of Edgewood High School in San Antonio in protest of inadequate resources and lacking certified administrators.
July 10, 1968  Rodríguez and seven other Edgewood parents file a class action lawsuit against Edgewood ISD and condemn Texas’ school finance system unconstitutional.
January 1969 A three judge federal district court allows the Texas legislature (in session during this odd-numbered year) to address the issue. The legislature fails to resolve school finance issues.
December 23, 1971 A three-judge federal district court rules in favor of Rodriguez, and holds that the Texas school finance system is unconstitutional under the 14th Amendment, arguing education as a “fundamental right," yet the state of Texas appeals the case to the Supreme Court.
March 21, 1973 In a 5-4 decision, the Supreme Court rules in favor of the defendants, declares no constitutional violation in Texas’ school financing system, and rejects the argument that education is a “fundamental right”.
May 23, 1984 In Edgewood ISD v. Kirby, the Mexican American Legal Defense and Educational Fund (MALDEF) sues, William Kirby, commissioner of education, for maintaining an unfair state public school financing system.
January 22, 1992 The Supreme Court rules Texas’ school finance methods unconstitutional in a 7-2 decision.

Resources

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