Federal Education Policy and the States, 1945-2009
The Nixon Years: School Funding - San Antonio v Rodriquez
The class action in Serrano extended the classification of "wealth discrimination" to every child in the state except those who lived in the one district offering "the greatest educational opportunity of all school districts within California." In this way, it implied that, in order to avoid charges of discrimination, the state would have to aid each school up to the level of the one with the highest expenditures per pupil. The ruling in Serrano v. Priest prompted similar litigation in other states-and, eventually, one of these suits made it to the U.S. Supreme Court. In 1973, the high court heard arguments in the case of San Antonio Independent School District v. Rodriguez, but, unlike the state supreme court in California, the U.S. Supreme Court found that, despite local disparities in school aid and differences in tax effort throughout Texas, the state's system of school aid did not violate the equal protection clause of the Fourteenth Amendment. As Justice Powell wrote for the majority, Texas, "by its provision for state contributions to each district, assured a basic education for every child while permitting and encouraging vital local participation and control of schools through district taxation."
Since a "basic education for every child" was all that the Texas state constitution guaranteed, the U.S. Supreme Court ruled, the state system of school aid did not violate the law. Powell added that the Texas system, "which was similar to systems employed in virtually every other state, was not a product of purposeful discrimination [or intentional state action] against any class but, instead, was a responsible attempt to arrive at practical and workable solutions to educational problems." He concluded, therefore, that Texas's formula for state aid to schools did not jeopardize the key principle of "equal educational opportunities"-defined as equal access to a "basic minimum" of instruction-for all students. The Rodriguez decision struck a blow to all cases seeking resource equalization through the federal courts. It effectively limited the impact of the Serrano decision to the state of California (and California state constitutional law) and relegated all future cases dealing with school aid to state courts.