Basically Law

Read the opinion here.

Issue.  Does a state system of funding public education through local property taxes violate the Equal Protection Clause?

Background.  Texas, like many states, funds it public schools primarily through local property taxes.  Consequently, spending on public education is higher, per pupil, in wealthier school districts than in poorer districts.  Individuals sued and claimed such disparity in spending on public education violated the Equal Protection Clause.  Applying strict scrutiny, the District Court agreed.  The Supreme Court, on appeal, reversed.

Court's Analysis.  In order to apply strict scrutiny to this financing plan for public education, the plan must either disadvantage a suspect class or infringe upon a fundamental right that is either explicitly or implicitly protected by the Constitution.  The District Court found wealth to be a "suspect" classification and education a "fundamental interest" so it applied strict scrutiny.  The Supreme Court disagreed.

The Court noted that it has only considered wealth a "suspect" classification in a small narrow band of cases involving access to the courts.  Besides, there is no evidence that the poor only cluster in poor neighborhoods.  Some are dispersed in wealthier and commercial/industrial districts.  Further, there was no reliable evidence that spending on public education correlated with the quality of such education.  And, Equal Protection does not require absolute equality in spending.  Ultimately, wealth does not have any of the traditional indices of suspectness:

the class is not saddled with such disabilities, or subjected to such a history of purposeful unequal treatment or relegated such a position of political powerlessness as to command extraordinary protection from the majoritarian political process

Since wealth classification is not suspect, the Court turned to whether public education is a fundamental right.  Even though education may be the most important function of state and local governments, it does not follow that education is a fundamental right.  The question is whether education is a fundamental right guaranteed in the Constitution.  Those claiming it is a fundamental right argued that education is essential to the effective exercise of First Amendment freedoms and the intelligent utilization of the right to vote.  The Court, however, noted that the courts are not required to ensure "the most effective speech or the most informed electoral choice."  Still, no one is claiming that any school is not providing the basic educational requirements to ensure a sufficient exercise of Constitutional rights.  Thus, no one is being denied a fundamental right of education even if such a right exists.

Ultimately, public education has been a local issue for nearly a century and the Court would not intrude because of the existence of some inequality.  There is no taxation scheme that is free of all discriminatory impact.  In the end, the Court recognized:

[We] hardly need add that this Court action today is not to be viewed as placing its judicial imprimatur on the status quo.  The need is apparent for reform in tax systems which may well have relied too long and too heavily on local property tax.  [But] the ultimate solutions must come from the lawmakers and from the democratic pressures of those who elect them.