Martinez Ex Rel. Morales v. Bynum

Supreme Court of the United States
461 U.S. 321, 1983 U.S. LEXIS 158, 75 L. Ed. 2d 879 (1983)

ELI5:

Rule of Law:

A state may impose a bona fide residence requirement for tuition-free public education, and a statute that denies such education to minors whose primary purpose for living in a school district separate from their parents is to attend its schools constitutes a permissible residence requirement under the Equal Protection Clause.

Facts:

Roberto Morales, a United States citizen, was born in McAllen, Texas.
Morales' parents are Mexican citizens who reside in Reynosa, Mexico.
In 1977, Morales moved from Mexico to McAllen, Texas, to live with his adult sister, Oralia Martinez.
The primary purpose for Morales moving to McAllen was to attend the public schools in the McAllen Independent School District.
Martinez is Morales' custodian but is not his court-appointed legal guardian and does not wish to become one.
The McAllen Independent School District denied Morales' application for tuition-free admission based on a Texas statute.
The statute denies tuition-free admission to a minor living apart from a parent or guardian if their presence in the district is for the primary purpose of attending public school.

Procedural Posture:

Oralia Martinez, as next friend of Roberto Morales, and others sued the Texas Commissioner of Education and several school districts in the U.S. District Court for the Southern District of Texas.
The plaintiffs sought a declaration that Texas Education Code § 21.031(d) was unconstitutional on its face.
The District Court found the statute constitutional and entered judgment for the defendants.
The plaintiffs appealed to the U.S. Court of Appeals for the Fifth Circuit.
The Court of Appeals affirmed the District Court's judgment, upholding the statute.
The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.

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Issue:

Does a state law that denies tuition-free public education to a minor who lives apart from their parent or legal guardian for the primary purpose of attending school in that district violate the Equal Protection Clause of the Fourteenth Amendment?

Opinions:

Majority - Justice Powell

No, the state law does not violate the Equal Protection Clause of the Fourteenth Amendment. The Constitution permits a state to restrict eligibility for tuition-free education to its bona fide residents, and the challenged statute is a bona fide residence requirement that satisfies constitutional standards. The Court has consistently distinguished between impermissible durational residence requirements and permissible bona fide residence requirements. Public education is not a fundamental right, and this statute does not involve a suspect classification, so it is subject to rational basis review. The state has a substantial interest in assuring that services provided for its residents are enjoyed only by residents and in maintaining the quality of its local public schools. The Texas statute is more generous than a traditional residence requirement—which requires physical presence and an intent to remain—because it only excludes children whose primary purpose is attending school, while admitting those present for other temporary reasons.

Dissenting - Justice Marshall

Yes, the Texas statute violates the Equal Protection Clause. The statute deprives some children who are genuine residents of an education because of their motive for residing in the state, a classification not adequately justified by the state's asserted interests. The majority misinterprets the statute and misunderstands the distinction between residence and domicile; the statute imposes a standard more stringent than a traditional residence requirement. Furthermore, this standard is not applied uniformly; it creates a special burden only on children living apart from their parents for educational purposes, while other temporary residents are granted free education. Because education is a fundamental interest, the classification should be subjected to careful scrutiny, which it cannot survive as it is not narrowly tailored to the state's goals of preserving resources or preventing population fluctuations.

Concurring - Justice Brennan

The opinion joins the majority but emphasizes that the case involves only a facial challenge to the statute. The Court's decision does not address the statute's validity as applied to specific factual contexts, particularly that of Roberto Morales, a U.S. citizen whose parents are nonresident aliens. Such a specific application might implicate a different set of constitutional considerations that could significantly affect the analysis.

Analysis:

This decision solidifies the principle that states can use 'bona fide residence requirements' to limit access to public services like education, distinguishing them from unconstitutional durational requirements that penalize the right to travel. The key significance is the Court's validation of a 'primary purpose' test as a legitimate tool for defining residency in the public school context. This ruling provides states a clear method to prevent 'school shopping' across districts without violating the Equal Protection Clause, reinforcing that public education is not a fundamental right that would trigger strict scrutiny for such classifications.

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