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San Antonio Independent School District v. Rodriguez

In 1968, a group of parents led by Demetrio Rodriguez, a longtime equal rights community activist, filed a lawsuit against the Edgewood Independent School District, a low-income, predominately Latinx district in San Antonio, Texas, and six other school districts, arguing that the state’s school finance system was inequitable. Specifically, the argument at the center of the case was the notion that education is a federal right as it is necessary in order to be an engaged citizen. Moreover, as the Texas state school finance system relied on local property tax for school funding, districts like Edgewood that are located in predominately low-income areas have low tax bases and are therefore underfunded and underresourced, which impacts necessary levels of education provided to students. As a result, children in low-wealth school districts are at an extreme disadvantage as compared to their peers in wealthier school districts. The case eventually made its way all the way to the U.S. Supreme Court where, in a five-four ruling, the justices decided that the system did not violate the Equal Protection Clause as Texas was not refusing to provide education to low-income students and the U.S. Constitution does not specifically state education to be a fundamental right (San Antonio Independent School District v. Rodriguez, 1973). The Court also stated “whether there is a correlation between expenditures and education quality is not one the federal courts should consider” (Rebell, 2017, p. 186). Since the Rodriguez ruling, there have been seven court cases with Texas school districts suing over the state’s finance system that have reached the Texas Supreme Court and the Edgewood district is still inequitably funded (Swaby & Ura, 2018). In the state’s most recent case, two-thirds of Texas school districts claimed that the current finance system does not meet the adequacy and suitability requirements outlined in the Texas Constitution. In its ruling, the Texas Supreme Court upheld the school funding system with one of thejustice’s stating in the opinion, “Our Byzantine school funding ‘system’ is undeniably imperfect, with immense room for improvement. But it satisfies minimum constitutional requirements” (Morath v. Texas Taxpayer & Student Fairness Coalition, 2016, p. 99). Multiple states have also tried to overturn Rodriguez but have been unsuccessful or the cases remain outstanding (Martin et al., 2018).

Edgewood Independent School District v. Kirby

Following the Rodriguez ruling, in 1984 the Mexican American Legal Defense and Educational Fund filed a suit on behalf of the Edgewood Independent School arguing that the Texas school finance system and its reliance on local property taxes to fund schools was discriminatory and inequitable. When the case began, there were 21 parents and eight school districts involved; this number grew to 67 additional school districts and several other parents and students (The Texas Politics Project, n.d.). In 1989, the Texas Supreme Court ruled the finance system as unconstitutional, noting that property wealth per student in Edgewood ISD was considerably lower than Alamo Heights Independent School District, one of the wealthiest districts in the same county as Edgewood and the state of Texas. The court ordered the state legislature to devise an equitable system by the 1990-91 school year.

The Texas Legislature created a plan that became known as the “Robin Hood” plan, in which money would be redistributed from affluent districts to low-wealth districts in order to equalize funding. While Texas was able to reduce funding disparities between affluent and low-wealth districts, the Robin Hood plan proved unpopular and problematic among Texans. Property-wealthy districts who were set to lose money over the plan argued it was illegal and eventually the court sided with them. In 1993, a new plan was signed into law in which school districts would seek to equalize funding through one of five options:

  • (1) merging its tax base with a poorer district, (2) sending money to the state to help pay for students in poorer districts, (3) contracting to educate students in other districts, (4) consolidating voluntarily with one or more districts, or (5) transferring some of its commercial taxable property to another district’s tax rolls.
  • (The Texas Politics Project, n.d.)

Over time, as previously stated, there would be many iterations of the Edgewood case argued over equitable, and later on, adequate school funding in Texas. Yet, as state funding for education declined and, as previously mentioned, the Texas Supreme Court eventually ruled that while the system may be “undeniably imperfect” it meets the basic requirements as set forth in the state constitution, disparities continue for students in Edgewood (Swaby & Ura, 2018).

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