Serrano v. Priest
96 Cal. Rptr. 601, 487 P.2d 1241, 5 Cal. 3d 584 (1971)
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Rule of Law:
A state public school financing system that relies heavily on local property taxes, creating vast disparities in per-pupil expenditures between school districts based on their assessed property wealth, violates the equal protection clauses of the Fourteenth Amendment of the U.S. Constitution and the California Constitution by making education quality a function of wealth, thereby discriminating against the poor and conditioning a fundamental interest on wealth without a compelling state purpose.
Facts:
- California's public school system obtains over 90% of its funds from local district taxes on real property and aid from the State School Fund.
- The amount of revenue a school district can raise from local property taxes largely depends on the assessed valuation of real property within its boundaries, which varies widely across the state (e.g., from $103 to $952,156 per elementary school pupil in 1969-1970).
- The state's 'foundation program' provides basic state aid ($125 per pupil) to all districts and equalization aid to poorer districts to achieve a minimum spending level ($355 for elementary, $488 for high school pupils).
- Despite state aid, significant differences in per-pupil revenue and educational expenditures persist; for example, in 1968-1969, Baldwin Park Unified School District spent $577.49 per pupil, while Beverly Hills Unified School District spent $1,231.72 per child.
- Districts with smaller tax bases (e.g., Baldwin Park with $3,706 assessed valuation per child) often levy much higher tax rates (e.g., $5.48 per $100 of assessed valuation) but still spend less on education than wealthier districts (e.g., Beverly Hills with $50,885 per child, taxing at $2.38 per $100).
- Plaintiff children attend public schools in Los Angeles County districts where, as a direct result of the financing scheme, the educational opportunities are substantially inferior to those in many other districts.
- Plaintiff parents, residents and taxpayers in Los Angeles County, are required to pay a higher tax rate than taxpayers in many other districts to secure the same or lesser educational opportunities for their children.
Procedural Posture:
- Plaintiffs (Los Angeles County public school children and their parents) filed a class action in trial court against state and county officials, seeking declaratory and injunctive relief, arguing the school financing system was unconstitutional.
- Defendants filed general demurrers, asserting the complaint failed to state facts sufficient to constitute a cause of action.
- The trial court sustained the demurrers, granting plaintiffs leave to amend their complaint.
- Plaintiffs failed to amend their complaint.
- The trial court granted defendants' motion for dismissal.
- An order of dismissal was entered by the trial court.
- Plaintiffs appealed the dismissal.
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Issue:
Does California's public school financing system, which largely depends on local property taxes and leads to substantial disparities in per-pupil revenue among school districts, violate the equal protection clauses of the U.S. and California Constitutions?
Opinions:
Majority - Sullivan, J.
Yes, California's public school financing system, with its substantial dependence on local property taxes and resulting wide disparities in school revenue, violates the equal protection clauses of both the Fourteenth Amendment of the U.S. Constitution and the California Constitution. The court determined that this funding scheme invidiously discriminates against the poor because it makes the quality of a child’s education a function of the wealth of his parents and neighbors. The right to an education in public schools is recognized as a fundamental interest which cannot be conditioned on wealth. Therefore, the court found no compelling state purpose necessitating the present method of financing and concluded that such a system cannot withstand constitutional challenge. The court applied the 'strict scrutiny' equal protection standard, finding that wealth is a suspect classification and education is a fundamental interest. The state's arguments for local administrative and fiscal control were rejected; local administrative control can be maintained regardless of financing, and 'local fiscal freewill' is a cruel illusion for poor districts unable to tax themselves into educational excellence. The court distinguished federal summary affirmances in McInnis v. Shapiro and Burruss v. Wilkerson, noting they focused on 'educational needs' as a nonjusticiable standard, whereas this case focused on wealth as a suspect classification affecting a fundamental interest.
Dissenting - McComb, J.
No, the judgment of the trial court should be affirmed. Justice McComb would have affirmed the judgment for the reasons expressed in the Court of Appeal opinion in Serrano v. Priest (Cal. App.) 89 Cal.Rptr. 345, which was prepared by Justice Dunn.
Analysis:
This case marked a groundbreaking expansion of equal protection jurisprudence by being one of the first state supreme courts to declare education a fundamental interest and wealth a suspect classification for equal protection purposes under state and federal constitutions. Although the U.S. Supreme Court later rejected Serrano's federal constitutional analysis in San Antonio Independent School District v. Rodriguez, this decision remains highly influential as precedent for challenges to school financing systems under state equal protection clauses. It highlighted how systems based on local property wealth inherently disadvantage students in poorer districts, advocating for greater equity in educational funding. The ruling spurred numerous similar lawsuits in other states and significantly influenced public policy discussions around school finance reform.
