EDGEWOOD ISD V. KIRBY (1989) CASE SUMMARY

In 1968, Demetrio Rodriguez and other parents of Mexican American students in the Edgewood Independent School District of San Antonio, Texas, filed a class action suit in U.S. District Court challenging Texas’ public school finance system. Under the Texas system, the state appropriated funds to provide each child with a minimum education. Each local school district then enriched that basic education with funds derived from locally levied ad valorem property taxes. Since the value of taxable property and the number of school-aged children varied greatly among the state’s many school districts, significant interdistrict disparities existed in available enrichment revenues, per-pupil expenditures, and tax rates.

The plaintiffs argued that this led to better education for students in wealthier school districts and worse education for students in poorer districts and was thus a violation of the equal protection of the law of the Fourteenth Amendment to the U.S. Constitution. A three-judge panel of the U.S. District Court unanimously ruled that education was a fundamental constitutional right and that wealth-based classifications such as Texas had created were constitutionally suspect. On appeal, the U.S. Supreme Court in 1973 in San Antonio Independent School District v. Rodriguez by a 5-4 vote reversed the lower court’s decision and thus sustained Texas’ public school finance system. The majority held that education is not a fundamental right since it is neither explicitly nor implicitly guaranteed by the U.S. Constitution.

In the decade after Rodriguez, Texas enacted a series of “equalization” reforms but failed to reduce significantly the interdistrict inequities in access to resources, per-pupil expenditures, and tax rates. With recourse to the U.S. Constitution and federal courts foreclosed by virtue of the U.S. Supreme Court’s decision in Rodriguez, the Mexican American Legal Defense and Education Fund (MALDEF) on behalf of the Edgewood Independent School District, other school districts, Rodriguez, and other parents of Mexican American students filed suit in a Texas District Court against Texas Commissioner of Education William Kirby and others. They argued that the state’s public school finance system violated the Texas Constitution. In 1987, the District Court ruled in favor of the plaintiffs by finding Texas’ public school finance system unconstitutional. The District Court ordered the Texas Legislature to formulate a more equitable system by 1989. The state appealed this decision to a three-judge panel of Texas’ Third Court of Appeals, which reversed the District Court’s judgment on grounds that education was not a basic right and furthermore ruled that Texas’ system of public school finance was constitutional. The Edgewood Independent School District and the other plaintiffs appealed to the Texas Supreme Court.