Serrano v. Priest
557 P.2d 929, 18 Cal. 3d 728, 135 Cal. Rptr. 345 (1976)
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Rule of Law:
A public school financing system that makes the quality of a child's education a function of the wealth of their school district violates the equal protection provisions of the California Constitution, as education is a fundamental interest under state law.
Facts:
- California's public school funding system relied heavily on local property taxes, supplemented by state aid.
- The amount of revenue a school district could raise from property taxes depended directly on the assessed valuation of property within its borders.
- This system created vast disparities; in Los Angeles County, the assessed valuation per pupil ranged from $3,706 in Baldwin Park to $50,885 in Beverly Hills.
- The state's 'foundation program' provided a flat grant of 'basic aid' to all districts and 'equalization aid' to poorer districts to ensure a minimum funding level, but this was insufficient to offset the wealth-based inequalities.
- As a result of these disparities, per-pupil expenditures varied widely, with Baldwin Park spending $577.49 per pupil while Beverly Hills spent $1,231.72 per pupil in the same year.
- Following the first Serrano decision, the legislature enacted S.B. 90 and A.B. 1267, which increased the foundation levels and imposed revenue limits on high-spending districts.
- The new system retained the 'basic aid' component and allowed districts to pass 'voted overrides' to raise additional revenue, a mechanism that favored wealthier districts who could raise more money with a smaller tax rate increase.
Procedural Posture:
- Plaintiffs, a group of public school children and their parents, filed a class action lawsuit in the Superior Court of Los Angeles County (a state trial court) against state and county officials.
- The trial court sustained the defendants' demurrers without leave to amend and entered a judgment of dismissal.
- Plaintiffs appealed to the California Supreme Court, which in Serrano v. Priest (1971) ('Serrano I'), reversed the trial court's dismissal and remanded the case for trial.
- Following a lengthy trial, the Superior Court found the California school financing system, including post-Serrano I legislative amendments, unconstitutional under the California Constitution and entered judgment for the plaintiffs.
- The defendant officials (appellants) appealed that judgment to the California Supreme Court.
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Issue:
Does California's public school financing system, which results in substantial disparities in per-pupil expenditures based on local school district property wealth, violate the equal protection provisions of the California Constitution?
Opinions:
Majority - Sullivan, J.
Yes, the California public school financing system violates the equal protection provisions of the California Constitution. This court adheres to its determination in Serrano I that education is a fundamental interest and that discrimination in educational opportunity based on district wealth constitutes a suspect classification under the California Constitution, thus requiring strict scrutiny. The U.S. Supreme Court's decision in Rodriguez, which held otherwise under the federal constitution, does not control the interpretation of California's independent state constitutional guarantees. The state's asserted interest in 'local control' is not compelling because the financing system provides a 'cruel illusion' of choice for poor districts, which cannot afford to tax themselves into providing a high-quality education. The legislative reforms of S.B. 90 and A.B. 1267 failed to cure the system's constitutional defects, as they perpetuated wealth-based disparities and the inequitable impact of voted tax overrides.
Dissenting - Richardson, J.
No, the California public school financing system does not violate the state constitution. The very same constitution that contains the general equal protection clause also contains specific provisions, namely Article XIII, section 21, that expressly authorize the essential elements of the challenged system of local district taxation for schools. A specific constitutional provision authorizing a particular system must prevail over a general provision. The majority's holding creates an irreconcilable conflict within the constitution itself. The court should defer to the Legislature on complex matters of fiscal and educational policy, which is a power vested in that branch by the constitution.
Dissenting - Clark, J.
No, the financing system does not violate the state constitution because it represents a rational legislative balance of the competing goals of funding equality, local control, and fiscal responsibility. Approximately 90% of school funding is equalized under the system, leaving only a minor 10% disparity which is justified by the compelling interest in preserving local decision-making. The majority's demand for absolute equality is unobtainable without sacrificing local control or risking state insolvency. Furthermore, the decision will have the perverse effect of transferring resources from poorer urban districts with high commercial property values to more affluent suburban districts with lower assessed valuations, effectively taking from the poor to give to the more fortunate.
Analysis:
This decision established education as a fundamental right under the California Constitution, creating a divergence from federal equal protection jurisprudence post-San Antonio School District v. Rodriguez. It enshrined the principle of 'fiscal neutrality,' mandating that the state's school funding mechanism cannot be a function of school district wealth. The ruling compelled a complete legislative overhaul of public school finance in California, shifting significant financial control from local districts to the state level and setting a major precedent for other states to challenge their own funding systems under their respective state constitutions.
