Educational Funding

John Serrano’s daughter was a student in the Baldwin Park Unified School District, a mostly working-class district without large property tax revenues. He became concerned that she was receiving an education inferior to that of students in some wealthier districts, such as Beverly Hills. He filed suit in superior court against the state treasurer, Ivy Baker

Priest, alleging that his rights as a parent were being violated. His case eventually reached the California Supreme Court. In 1971, the court handed down its decision in Serrano v.

Priest.1 The court held that education was a “fundamental interest” and that disparities in funding from one district to another discriminate against those in districts like Baldwin

Park with a weak tax base. The court held that this violated equal protection of the laws, a right found in both the federal and state constitutions.2 Courts in several other states reached the same conclusion, as did a federal district court in a Texas case. In 1973, however, the U.S. Supreme Court rejected this position. Referring specifically to Serrano and similar cases, the court said that the courts in these cases had reached their findings through “a simplistic process of analysis.”3

Because of the “independent grounds” doctrine, this criticism, though quite pointed, did not invalidate the California Supreme Court’s interpretation of the state constitution, and so the Serrano decision stood. The case was returned to superior court for implementation. Eventually, that court ruled that changes in school funding laws had brought the state into basic compliance with the ruling, although for a variety of reasons significant differences in funding among districts still remain.4 1. Serrano v. Priest 5 Cal. 3d 584 (1971). 2. U.S. Constitution, amend. 14; California Constitution, art. I, sect. 7. 3. San Antonio Independent School District v. Rodriguez 411 U.S. 1 (1973). 4. David G. Savage, “School Finance System Upheld,” Los Angeles Times, 29 April 1983; Steven B. Frates, “School Budgets Get Caught in Political Mire,” Los Angeles Times, 3 September 2000.