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Background • This lawsuit was brought by members of the Edgewood Concerned Parent Association representing their children and similarly situated students. The suit was filed on June 30, 1968 in the federal district court for the Western District of Texas. In the initial complaint, the parents sued San Antonio ISD, Alamo Heights ISD and five other school districts, the Bexar County School Trustees and the State of Texas contending the “Texas method of school financing violated the equal protection clause of the Fourteenth Amendment to the U. S. Constitution.” The lawsuit alleged that education was a fundamental right and that wealth-based discrimination in the provision of education (e.g., a fundamental right), created in the poor, or those of lesser wealth, a constitutionally suspect class, who were to be protected from the discrimination. Eventually, the school districts were dropped from the case leaving only the State of Texas as the defendant. The case advanced through the courts system, providing victory to the Edgewood parents until it reached the Supreme Court in 1972. The school districts in the San Antonio area, and generally in Texas, had a long history of financial inequity. Rodriguez presented evidence that school districts in the wealthy, and primarily white, areas of town, most notably the north-side Alamo Heights Independent School District, were able to contribute a much higher amount per child than Edgewood, which was a poor minority area. From the trial brief, Dr. Jose Cardenas, Superintendent of Schools, Edgewood Independent School District testified to the problem in his affidavit, the following information: • Edgewood is a poor district with a low tax base. As a result, its ad valorem tax revenue fall far short of the monies available in other Bexar County school districts. With this inequitable financing of its schools, Edgewood cannot hire sufficient qualified personnel, nor provide the physical facilities, library books, equipment and supplies afforded by other Bexar County District. • To illustrate the Edgewood residents are making a high tax effort, have burdened themselves with one of the highest proportion of bonded indebtness in the county to pay for capital improvements and, never, in the history of the district have they failed to approve a bond issue.
Question? Did Texas public education finance system violate the 14th Amendment’s Equal Protection Clause by failing to distribute funding equally among its school districts?
The 14th Amendment? • It was passed by Congress on June13, 1866 and ratified on July 9, 1868. • You are a citizen of the United States and the State you live in, if you where either born in the United States or become a naturalized citizen • No state can make or enforce any law which shall abridge the privileges or immunities of citizens of the United States • No state can deprive an person of life, liberty or the property without due process of law • No state can deny to any person the equal protection of the law
Conclusion / Decision • The Supreme Court ruled five to four against Rodriguez on March 21, 1973. The Court stated that the system of school finance in the state of Texas did not violate the federal constitution, nor did it systematically discriminate against all poor Texas children. Justice Powell argued that on the issue of equity, the Equal Protection Clause did not necessitate absolute equality in the funding of education. In the eyes of the Court, the issue of school funding was to be resolved by the state. The Court refused to examine the system of school finance with strict scrutiny due to the fact that there is no fundamental right to education in the Constitution.
Significance The Supreme Court appeared to uphold inequity in education funding People in poorer districts suffer most from the decision
What it led to? • Many states have since reformed their funding systems • The Supreme Court made it more difficult to bring cases on behalf of groups who have been discriminated against, since this case. • In 1989 the Texas Supreme Court held that the state needs to redo the education funding system to have closer per-pupil expenditures throughout the state.
Other Court Cases • ROBISON V CAHIL (1973)The New Jersey Supreme Court decision in this case held that the school's finance system violated the education clause in the state's constitution, which guaranteed an equal opportunity to receive a thorough and efficient system of public education. The court held that the state was constitutionally obliged to ensure this opportunity, whatever the condition of local taxing policy or district funding decisions. Although the concept of adequacy was an element in this decision, it was an undefined element • EDGEWOOD ISD V. KIRBY(1984)-The plaintiffs contested the state's reliance on local property taxes to finance its system of public education, contending that this method was unequal because property values varied greatly from district to district, thus creating an imbalance in funds available to educate students on an equal basis throughout the state. The court's unanimous decision upheld the plaintiff's claims and ordered the state legislature to come up with a plan by the next school year. The final plan capped the amount of money that districts can raise locally through property tax, and redistributed funds from some high-wealth school districts to low-wealth school districts.
More Court Cases • MCDUFFY V. SECRETARY OF THE EXECUTIVE OFFICE OF EDUCATION(1993) • Plaintiffs from 16 low-wealth districts in Massachusetts alleged that their schools were insufficiently funded and that the education provided with those resources was inadequate by any reasonable standard of adequacy. The court declared that the Commonwealth was not currently fulfilling this constitutional duty. The state was directed to devise a plan with sources of funds sufficient to meet the constitutional mandate, and the court of entry was authorized to determine whether, within a reasonable time, appropriate legislative action had been taken. • ABBOT V. BURKE(1994) • This case extended the decision in Robinson, ruling that all children must have an equal opportunity that equips children for their roles as citizens and competitors in the contemporary labor market. This ruling provided a definition for adequacy and established a rationale for requirements that New Jersey provide for the educational needs of disadvantaged students by providing additional funding using supplemental remedial measures for the poorer districts in the state.
LEANDRA V. STATE OF NORTH CAROLINA(1997) • Alleged that the education finance system in the state was to blame for the physical deterioration of their schools, a lack of basic supplies and essential teaching equipment, and the inability to attract high-quality teachers. These conditions deprived children in their districts equal or adequate education as provided by provisions in the state constitution. The court held that North Carolina's children have a right to a sound basic education as a minimum standard of quality and that the state had an obligation to provide a sound basic education applied equally to the children in every North Carolina school district. The decision made it clear that districts may spend local money to provide an education that is even better than the required minimum. • CAMPAIGN FOR FISCAL EQUITY, et al V. STATE BOF NEW YORK, et al (1993) • This was the first case to link standards reform to adequate funding. Plaintiffs alleged State failed to provide students with a sound basic education as required by the state constitution. The aid formula provide lower-than-average funding, and thereby discriminated against minority students, who are disproportionately affected by the funding pattern. The court found the state financing system did not comply with education provisions in the state constitution.
Connection to Maine Finance • The Essential Programs and Services formula that Maine uses to finance its schools does not discriminate among school communities in Maine, therefore it guarantees equality based on economic diversity. The Fourteenth Amendment is upheld in the State of Maine in regards to Equal Protection Clause. • The EPS formula determines that adequate funding is provided for all students in Maine to receive a free appropriate education.
