Plyler v. Doe
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| Plyler v. Doe | |
| Docket number: 80-1538 | |
| Court: United States Supreme Court | |
| Court membership | |
| Chief Justice Warren E. Burger Associate Justices William Brennan • Byron White • Thurgood Marshall Harry Blackmun • Lewis Powell William Rehnquist • John Paul Stevens • Sandra Day O'Connor | |
Plyler v. Doe was a United States Supreme Court case regarding state-provided funding for local school districts. At issue was whether it was a violation of the Constitution to withhold state funding from school districts that educated children residing in the country without legal permission.
The court limited oral arguments to the following question:
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In a 5-4 decision issued on June 15, 1982, the court held that withholding state funds for local school districts that educated children residing in the country without legal permission was a violation of the Equal Protection Clause of the Fourteenth Amendment.[2]
Background
In May 1975, the state of Texas enacted a law withholding from local school districts state funds that would be used for the education of children who were residing in the country without legal permission. Under the law, these children could also be denied enrollment in public school at the school district's discretion.[1]
A class-action lawsuit was filed in the United States District Court for the Eastern District of Texas on behalf of school-age children from Mexico who were residing in Smith County, Texas. The children were unable to prove that they had been admitted into the country with legal permission. The lawsuit argued that denying a free education to such children violated the Equal Protection Clause of the Amendment XIV, United States Constitution. The Equal Protection Clause sets forth that no state shall "deny to any person within its jurisdiction the equal protection of the laws."[1]
The district court held that the class of children were protected under the Equal Protection Clause and that the Texas state law violated that clause. The court found that the law was not supported by a rational basis because it did not result in lower levels of illegal immigration, nor did it necessarily lead to higher quality education. The court issued an injunction to block enforcement of the law. On appeal, the United States Court of Appeals for the 5th Circuit affirmed.[1]
The ruling was appealed to the United States Supreme Court, which agreed to hear the case.
Decision
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In a 5-4 decision issued on June 15, 1982, the Supreme Court ruled in favor of the class of school-age children. The majority opinion was written by Justice William Brennan, who was joined by Justices Thurgood Marshall, Harry Blackmun, Lewis Powell, and John Paul Stevens.
In its opinion, the Supreme Court held that withholding state funds from local school districts for the education of children residing in the country without legal permission violated the Equal Protection Clause of the Fourteenth Amendment. Such children, though not United States citizens, are persons "in any ordinary sense of the term," and thus protected by the Equal Protection Clause, the court wrote:[1]
| “ | The Fourteenth Amendment's protection extends to anyone, citizen or stranger, who is subject to the laws of a State, and reaches into every corner of a State's territory.[3] | ” |
| —Supreme Court of the United States | ||
The court also held that the statute was not established on a rational basis because it did not further the stated goals of reducing illegal immigration, saving the state money, and increasing the quality of education. By denying the relevant class of children an education, the state caused a lifetime of hardship on a class of children who were residing in the country by no decision of their own. This in turn harmed the nation as a whole, the court found.[1]
The law was struck down and the judgement of the Fifth Circuit was affirmed.[1]
Dissent
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The dissent was written by Chief Justice Warren E. Burger, who was joined by Justices Byron White, William Rehnquist, and Sandra Day O'Connor.
In his opinion, Burger argued that the majority opinion in effect set social policy and that court had no business assuming a policymaking role. He also wrote that it is not up to the court to provide the effective leadership that Congress had failed to do in addressing what he identified as "serious national problems" associated with illegal immigration. Burger further argued that the "Equal Protection Clause does not mandate identical treatment of different categories of persons" and that Texas had a legitimate reason to distinguish between individuals who were residing in the country with and without legal permission.[1]
See also
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Footnotes
