Advocacy Paper: Antonio versus Rodriguez



Advocacy Paper: Antonio versus Rodriguez

Brief Fact Summary

A Texas system of financing public education was held constitutional by the Supreme Court of the United States (Supreme Court) even though it produced substantial inter-district disparities in per-pupil expenditures, stemming from the differences in property values among the district.

Thesis Statement/Synopsis of Rule of Law

 Education-based classifications are not fundamental rights. Therefore, the proper judicial standard to test such classifications is minimum rationality. This paper seeks to convey the richness of the many stories and perspectives that collectively comprise Rodriguez. I first describe the major parties as well as the initial lawsuit in federal district court (Kurland, 1968). I then turn to the judicial opinions generated by the district court and U.S. Supreme Court. A comparison of the two opinions reveals decidedly different approaches to such issues as judicial capacity, fundamental rights, and federalism. I also consider the opinions' practical consequences and place them into the broader legal context, especially with respect to the concurrent school desegregation

Facts

Mexican-American parents of children in the Edgewood School District in San Antonio sued on behalf of children of poor families residing in districts having a low property tax base. The challengers attacked the constitutionality of the Texas system of financing public education, which relied heavily on such property taxes. Specifically, the challengers claimed that the system violated equal protection because it produced substantial inter-district disparities in per-pupil expenditures, stemming from the differences in property values among the district (Kurland, 1968). Although contributions from a statewide “minimum foundation school program” served to reduce inter-district disparities, district spending continued to vary considerably on the basis of property wealth. The District Court, exercising strict scrutiny, held that the Texas scheme violated equal protection.

Issue

Whether the Texas system of financing public education operates to the disadvantage of some suspect class? Whether the Texas system of financing public education impinges upon a fundamental right explicitly or implicitly protected by the United States Constitution (Constitution)?

Held

No. Judgment of the District Court reversed. The system of alleged discrimination and the class it defines have none of the traditional indicia of suspectness: the class is not saddled with disabilities, or subjected to 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. Therefore, the Texas system does not operate to the peculiar disadvantage of any suspect class (Craig & Bruce, ...