Summary of San Antonio Ind. School Dist. v. Rodriguez

Facts:

State legislature established a program in which 80% of a school’s funding comes from the state and the other 20% is based on local property taxes.  Edgewood school district has much less tax-paying ability than Alamo Heights, and thus gets less funding per pupil.  

Procedural History:

The District Court found wealth to be a suspect class and education a fundamental interest and therefore found that it could only be sustained on a showing of a compelling state interest.  Ruled unconstitutional.

Issue:

Does the disparate quality of the two school districts violate the EPC?

Holding :

Don’t apply judicial scrutiny.  A system which assured basic education for every child in the state and permitted and encouraged participation in and significant control of each district's schools at local level bore a rational relationship to legitimate state purpose and doesn’t violate EPC.

Reasoning:

1. wealth is not a suspect classification
   1. It isn’t saddled with disabilities or subject to a history of purposeful discrimination. 
   2. They say even if we would consider wealth a suspect classification, there’s no wealth classification here – at most, it’s classification by wealth of the district and we couldn’t count that. 
2. education is not a fundamental right. 
   1. They say it’s not directly in the constitution so it’s not a fundamental right… but isn’t that true of a lot of so-called fundamental rights? 
   2. The key to discovering whether something is fundamental is not to be found by comparing it in social significance to other rights, but rather by assessing whether there is a right to it explicitly or implicitly guaranteed by the Constitution. 
   3. Some contend that because it has a bearing on other rights in the constitution (first amendment free speech, voting rights), it should be protected too.  But, the citizenry isn’t guaranteed to most effective speech or the most informed electoral choice. 

The state is only required to provide minimally adequate educational opportunities, and it does so.  

Judgment:

Reversed.

Comments:

Brennan dissent:  Don’t agree with the statement that to be fundamental it must be explicitly guaranteed in the constitution.  

Marshall dissent: 

• Don’t agree with the statement that to be fundamental it must be explicitly guaranteed in the constitution.  Should determine the extent to which constitutionally guaranteed rights are dependent on interests not mentioned in the constitution and apply a sliding scale of strictness as is appropriate. 
• Education is fundamental because it is afforded unique status in our society and has a close relationship to other fundamental rights. 
• He says “both the nature of the interest and the classification”.  Promotes a spectrum of standards – “sliding scale scrutiny.” 
• Might also explain out-of-state-education cases: there’s a difference in importance between welfare benefits and eligibility for in-state tuition.  When we’re making a judgment we can consider that difference even though we haven’t said welfare is fundamental/out-of-state status is a suspect classification.