San Antonio v. Rodriguez and the Legal Geography of School Finance Reform

Abstract

It is easy to forget that important Supreme Court cases involve people; it is even easier to forget that they are rooted in particular places. Every case begins somewhere, and San Antonio v. Rodriguez is no exception. Rodriguez was both a product and reflection of the long history of territorial struggle in San Antonio and borderland Texas. Two geographic and jurisdictional places - both nominally part of the city of San Antonio, but conceptually distinct from it - became the surrogates for that contest. On the West Side, populated predominantly by poor Hispanics, was the Edgewood Independent School District, which spent less money per pupil than any school district in the county. And on the North Side was the almost exclusively white, wealthy Alamo Heights Independent School District, which spent more money per pupil than any school district in the county. These places would come to represent the racial geography of all of south Texas. They would also become doctrinally problematic in Rodriguez, as the majority and dissents wrestled with the distinction between poor places and poor people. That tension continues to dog school finance reform. Despite thirty-five years of effort, neither courts nor legislatures have been able to mediate the tensions between local control and equal access, the rights of individual children and the rights of communities, or the relative wealth of places and the relative wealth of people. This narrative of Rodriguez emphasizes the practical and doctrinal implications of San Antonio’s racial geography for that case. And it highlights the problem of geography for school finance reform more broadly.

Keywords: Legal History, Equal Protection, Supreme Court, Justice Powell, School Finance Reform, San Antonio