Opinion

San Antonio Independent School District v. Rodriguez

  • 411 U.S. 1
  • 93 S. Ct. 1278
  • 36 L. Ed. 2d 16
  • 1973 U.S. LEXIS 91
Court
Supreme Court of the United States
Filed
Apr 23, 1973
Status
Published
Author
Brennan
On the bench
Maeshall, Powell, Burger, Stewart, Blackmun, Rehnquist, Brennan, White, Douglas, Marshall
Cited by
3,154 cases

concluding that a class comprising poor families exhibits none of the “traditional indicia of suspectness” because class is not “saddled with such disabilities, or subjected to such a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process.”

How later courts described this case

  • concluding that a class comprising poor families exhibits none of the “traditional indicia of suspectness” because class is not “saddled with such disabilities, or subjected to such a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process.”
  • explaining that the key to discovering whether a particular right-in that case education-is "fundamental" is not to be found in comparisons of the relative societal significance of the right or weighing whether the right is as important as another right; the answer lies in assessing whether the right is explicitly or implicitly guaranteed by the Constitution
  • concluding that class comprised of poor families exhibits none of "traditional indicia of suspectness" because class is "not saddled with such disabilities, or subjected to such a history of purposeful unequal treatment, or relegated to such a position of political powerlessness as to command extraordinary protection from the majoritarian political process"
  • stating, in its rational-basis review of a school-funding system, that “this case ... involves the most persistent and difficult questions of educational policy, another area in which this Court’s lack of specialized knowledge and experience counsels against premature interference with the informed judgments made at the state and local levels”

Written by the judges who cited it.

Distinguished

  • Distinguished by Petrella v. Brownback, 980 F. Supp. 2d 1293 (2013)

    Plaintiffs argue that Rodriguez is distinguishable because in that case the plaintiffs sought more money from the state for public education, while in the present case, plaintiffs challenge their inability to provide additional local funds.
    District Court, D. KansasOct 29, 2013Read it
  • Distinguished by Connecticut Coalition for Justice in Education Funding, Inc. v. Rell, 295 Conn. 240 (2010)

    ” Id.; see also id., 35 (rejecting plaintiffs’ claim “that education is distinguishable from other services and benefits provided by the [s]tate because it bears a peculiarly close relationship to other rights and liberties accorded protection under the [constitution” specifically, “the effective exercise of [f|irst [ajmendment freedoms and to intelligent utilization of the right
    Supreme Court of ConnecticutMar 30, 2010Read it
  • Distinguished by State v. Brown, 135 N.M. 291 (2004)

    Thus, the dissent’s reliance on San Antonio Independent School District v. Rodriguez, 411 U.S. 1, 29, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973) is inapposite.
    New Mexico Court of AppealsMar 16, 2004Read it
  • Distinguished by Board of Education v. Nyquist, 83 A.D.2d 217 (1981)

    In this regard, we reject as misplaced the State’s reliance on Dorsey v Stuyvesant Town Corp. (299 NY 512, cert den 339 US 981) for the proposition that Rodriguez (411 US 1, supra) compels application of the “rational relationship” standard of equal protection review.
    Appellate Division of the Supreme Court of the State of New YorkOct 26, 1981Read it

The opinion

Mr. Justice Brennan,

dissenting.

Although I agree with my Brother White that the Texas statutory scheme is devoid of any rational basis, and for that reason is violative of the Equal Protection Clause, I also record my disagreement with the Court’s rather distressing assertion that a right may be deemed “fundamental” for the purposes of equal protection analysis only if it is “explicitly or implicitly guaranteed by the Constitution.” Ante, at 33-34. As my Brother Marshall convincingly demonstrates, our prior cases stand for the proposition that “fundamentality” is, in large measure, a function of the right’s importance in terms of the effectuation of those rights which are in fact constitutionally guaranteed. Thus, “[a]s the nexus between the specific constitutional guarantee and the non- *63 constitutional interest draws closer, the nonconstitutional interest becomes more fundamental and the degree of judicial scrutiny applied when the interest is infringed on a discriminatory basis must be adjusted accordingly.” Post, at 102-103.

Here, there can be no doubt that education is inextricably linked to the right to participate in the electoral process and to the rights of free speech and association guaranteed by the First Amendment. See post, at 111— 115. This being so, any classification affecting education must be subjected to strict judicial scrutiny, and since even the State concedes that the statutory scheme now before us cannot pass constitutional muster under this stricter standard of review, I can only conclude that the Texas school-financing scheme is constitutionally invalid.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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