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 is a United States Supreme Court case that was decided on June 15, 1982. The class action case concerned 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.[1][2] Click here for more information on the case background.
In a 5-4 decision, the Court struck down the Texas law and affirmed the judgment of the United States Court of Appeals for the Fifth Circuit. SCOTUS held that withholding state funds for local school districts that educated children residing in the country without legal permission violated the Equal Protection Clause of the Fourteenth Amendment.[1][2] Justice William Brennan delivered the opinion of the Court. Justices Harry Blackmun and Lewis Powell filed concurring opinions. Chief Justice Warren E. Burger filed a dissenting opinion, joined by Justices Byron White, William Rehnquist, and Sandra Day O'Connor. Click here for more information on the ruling.
Background
In May 1975, Texas enacted a law withholding state funds from local school districts that would be used to educate children 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][2][3]
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 Fourteenth Amendment. The Equal Protection Clause sets forth that no state shall "deny to any person within its jurisdiction the equal protection of the laws."[1][2][3]
The district court held that the class of children were protected under the Equal Protection Clause and that the Texas state law violated their rights. 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.[3]
The ruling was appealed to the United States Supreme Court, which agreed to hear the case.
Question presented
The court limited oral arguments to the following question:[3]
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Outcome
Opinion
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In a 5-4 ruling 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, joined by Justices Thurgood Marshall, Harry Blackmun, Lewis Powell, and John Paul Stevens. Justices Harry Blackmun and Lewis Powell filed concurring opinions. Chief Justice Warren E. Burger filed a dissenting opinion, joined by Justices Byron White, William Rehnquist, and Sandra Day O'Connor.[1][2]
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, while not United States citizens, are persons "in any ordinary sense of the term," and thus protected by the Equal Protection Clause. The Court concluded:[3]
| “ | 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.[4] | ” |
| —Supreme Court of the United States | ||
The court also held that the Texas 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 Court concluded, 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: "It is thus clear that whatever savings might be achieved by denying these children an education, they are wholly insubstantial in light of the costs involved to these children, the State, and the Nation."[3]
The law was struck down and the judgment of the Fifth Circuit was affirmed.[3]
Concurring opinion
Justice Blackmun
In his concurring opinion, Justice Blackmun wrote:[2]
| “ | Like JUSTICE POWELL, I believe that the children involved in this litigation "should not be left on the streets uneducated." Post at 457 U. S. 238. I write separately, however, because, in my view, the nature of the interest at stake is crucial to the proper resolution of these cases. ... In my view, when the State provides an education to some and denies it to others, it immediately and inevitably creates class distinctions of a type fundamentally inconsistent with those purposes, mentioned above, of the Equal Protection Clause. Children denied an education are placed at a permanent and insurmountable competitive disadvantage, for an uneducated child is denied even the opportunity to achieve. And when those children are members of an identifiable group, that group -- through the State's action -- will have been converted into a discrete underclass. Other benefits provided by the State, such as housing and public assistance, are, of course, important; to an individual in immediate need, they may be more desirable than the right to be educated. But classifications involving the complete denial of education are, in a sense, unique, for they strike at the heart of equal protection values by involving the State in the creation of permanent class distinctions. Cf. Rodriguez, 411 U.S. at 411 U. S. 115, n. 74 (MARSHALL, J., dissenting). In a sense, then, denial of an education is the analogue of denial of the right to vote: the former relegates the individual to second-class social status; the latter places him at a permanent political disadvantage. ... Because I believe that the Court's carefully worded analysis recognizes the importance of the equal protection and preemption interests I consider crucial, I join its opinion as well as its judgment.[4] |
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| —Justice Harry Blackmun | ||
Justice Powell
In his concurring opinion, Justice Powell wrote:[2]
| “ | I join the opinion of the Court, and write separately to emphasize the unique character of the cases before us. ... In my view, the State's denial of education to these children bears no substantial relation to any substantial state interest. Both of the District Courts found that an uncertain but significant percentage of illegal alien children will remain in Texas as residents, and many eventually will become citizens. The discussion by the Court of the State's purported interests demonstrates that they are poorly served by the educational exclusion. Indeed, the interests relied upon by the State would seem to be insubstantial in view of the consequences to the State itself of wholly uneducated persons living indefinitely within its borders. By contrast, access to the public schools is made available to the children of lawful residents without regard to the temporary nature of their residency in the particular Texas school district. [Footnote 3/4] The Court of Appeals and the District Courts that addressed these cases concluded that the classification could not satisfy even the bare requirements of rationality. One need not go so far to conclude that the exclusion of appellees' class [Footnote 3/5] of children from state-provided education is a type of punitive discrimination based on status that is impermissible under the Equal Protection Clause. In reaching this conclusion, I am not unmindful of what must be the exasperation of responsible citizens and government authorities in Texas and other States similarly situated. Their responsibility, if any, for the influx of aliens is slight compared to that imposed by the Constitution on the Federal Government. [Footnote 3/6] So long as the ease of entry remains inviting, and the power to deport is exercised infrequently by the Federal Government, the additional expense of admitting these children to public schools might fairly be shared by the Federal and State Governments. But it hardly can be argued rationally that anyone benefits from the creation within our borders of a subclass of illiterate persons, many of whom will remain in the State, adding to the problems and costs of both State and National Governments attendant upon unemployment, welfare, and crime.[4] |
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| —Justice Lewis Powell | ||
Dissenting opinion
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The dissent was written by Chief Justice Warren E. Burger, joined by Justices Byron White, William Rehnquist, and Sandra Day O'Connor. In his dissent, Chief Justice Burger wrote:[2]
| “ | Were it our business to set the Nation's social policy, I would agree without hesitation that it is senseless for an enlightened society to deprive any children -- including illegal aliens -- of an elementary education. I fully agree that it would be folly -- and wrong -- to tolerate creation of a segment of society made up of illiterate persons, many having a limited or no command of our language. [Footnote 4/1] However, the Constitution does not constitute us as "Platonic Guardians," nor does it vest in this Court the authority to strike down laws because they do not meet our standards of desirable social policy, "wisdom," or "common sense." See TVA v. Hill, 437 U. S. 153, 437 U. S. 194-195 (1978). We trespass on the assigned function of the political branches under our structure of limited and separated powers when we assume a policymaking role as the Court does today. The Court makes no attempt to disguise that it is acting to make up for Congress' lack of "effective leadership" in dealing with the serious national problems caused by the influx of uncountable millions of illegal aliens across our borders. ... I have no quarrel with the conclusion that the Equal Protection Clause of the Fourteenth Amendment applies to aliens who, after their illegal entry into this country, are indeed physically "within the jurisdiction" of a state. However, as the Court concedes, this "only begins the inquiry." Ante at 457 U. S. 215. The Equal Protection Clause does not mandate identical treatment of different categories of persons. Jefferson v. Hackney, 406 U. S. 535, 406 U. S. 549 (1972); Reed v. Reed, 404 U. S. 71, 404 U. S. 75 (1971); Tigner v. Texas, 310 U. S. 141, 310 U. S. 147-148 (1940). ... Congress, "vested by the Constitution with the responsibility of protecting our borders and legislating with respect to aliens," ante at 457 U. S. 237 (POWELL, J., concurring), bears primary responsibility for addressing the problems occasioned by the millions of illegal aliens flooding across our southern border. Similarly, it is for Congress, and not this Court, to assess the "social costs borne by our Nation when select groups are denied the means to absorb the values and skills upon which our social order rests." Ante at 457 U. S. 221; see ante at 457 U. S. 223-224. While the "specter of a permanent caste" of illegal Mexican residents of the United States is indeed a disturbing one, see ante at 457 U. S. 218-219, it is but one segment of a larger problem, which is for the political branches to solve. I find it difficult to believe that Congress would long tolerate such a self-destructive result -- that it would fail to deport these illegal alien families or to provide for the education of their children. Yet instead of allowing the political processes to run their course -- albeit with some delay -- the Court seeks to do Congress' job for it, compensating for congressional inaction. It is not unreasonable to think that this encourages the political branches to pass their problems to the Judiciary. The solution to this seemingly intractable problem is to defer to the political processes, unpalatable as that may be to some.[4] |
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| —Chief Justice Warren E. Burger | ||
See also
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External links
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 Oyez, "Plyler v. Doe," accessed July 9, 2025
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 United States Supreme Court, Plyler v. Doe, decided June 15, 1982
- ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 FindLaw, "Plyler v. Doe," archived July 9, 2025
- ↑ 4.0 4.1 4.2 4.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
