Serrano v. Priest
Encyclopedia
Serrano v. Priest refers to three cases decided by the California Supreme Court: Serrano v. Priest, 5 Cal.3d 584 (1971) (Serrano I); Serrano v. Priest, 18 Cal.3d 728 (1976) (Serrano II); and Serrano v. Priest, 20 Cal.3d 25 (1977) (Serrano III).
, Serrano v. Priest (John Serrano was a parent of one of several Los Angeles public school students; Ivy Baker Priest
was the California State Treasurer
at the time) set forth three causes of action (quotes from the decision).
The Court agreed with the plaintiffs, largely on equal-protection grounds, and returned the case to the trial court for further proceedings.
(1973), the Supreme Court of the United States
reversed a similar decision by a Texas District Court, which like Serrano I had been decided on Fourteenth Amendment equal-protection grounds. In Serrano I, however, the California Supreme Court had relied in addition on California's constitution, and in Serrano II they affirmed that basis, protecting the Serrano decisions from Rodriguez.
The Serrano II decision also held that the legislative response to Serrano I was insufficient, and affirmed the trial court's order requiring that wealth-based funding disparities between district be reduced to less than $100 by 1980.
, and an initial property-tax-based solution was replaced by a funding scheme that relied more heavily on state (as opposed to district) revenue, which has remained in effect, with occasional adjustments, ever since.
Serrano I (1971)
Initiated in 1968 in the Superior Court of Los Angeles CountySuperior Court of Los Angeles County
The Superior Court of Los Angeles County is the Superior Court located in Los Angeles County. It is the largest single unified trial court in the United States....
, Serrano v. Priest (John Serrano was a parent of one of several Los Angeles public school students; Ivy Baker Priest
Ivy Baker Priest
Ivy Baker Priest was an American political figure. Born in Kimberly, Utah, she was a member of The Church of Jesus Christ of Latter-day Saints....
was the California State Treasurer
California State Treasurer
The California State Treasurer is responsible for the state's investment and finance. The post has more narrow responsibilities and authority than the California State Controller...
at the time) set forth three causes of action (quotes from the decision).
- California's method of funding public education, because of district-to-district disparities, "fails to meet the requirements of the equal protection clause of the Fourteenth AmendmentFourteenth Amendment to the United States ConstitutionThe Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
of the United States Constitution and the California Constitution." - "[As] a direct result of the financing scheme they are required to pay a higher tax rate than [taxpayers] in many other school districts in order to obtain for their children the same or lesser educational opportunities afforded children in those other districts."
- "[That] an actual controversy has arisen and now exists between the parties as to the validity and constitutionality of the financing scheme under the Fourteenth Amendment of the United States Constitution and under the California Constitution."
The Court agreed with the plaintiffs, largely on equal-protection grounds, and returned the case to the trial court for further proceedings.
Serrano II (1976)
In San Antonio Independent School District v. RodriguezSan Antonio Independent School District v. Rodriguez
San Antonio Independent School District v. Rodriguez, 411 U.S. 1 , was a case in which the Supreme Court of the United States held that a school-financing system based on local property taxes was not an unconstitutional violation of the Fourteenth Amendment's equal protection clause...
(1973), the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
reversed a similar decision by a Texas District Court, which like Serrano I had been decided on Fourteenth Amendment equal-protection grounds. In Serrano I, however, the California Supreme Court had relied in addition on California's constitution, and in Serrano II they affirmed that basis, protecting the Serrano decisions from Rodriguez.
The Serrano II decision also held that the legislative response to Serrano I was insufficient, and affirmed the trial court's order requiring that wealth-based funding disparities between district be reduced to less than $100 by 1980.
Serrano III (1977)
Serrano III dealt primarily with attorneys' fees, but in passing affirmed the trial court's response to the Serrano II decision, including a six-year timetable for bringing the funding system into compliance.Proposition 13 (1978)
The legislative response to Serrano I and Serrano II was significantly constrained by California Proposition 13 (1978)California Proposition 13 (1978)
Proposition 13 was an amendment of the Constitution of California enacted during 1978, by means of the initiative process. It was approved by California voters on June 6, 1978. It was declared constitutional by the United States Supreme Court in the case of Nordlinger v. Hahn,...
, and an initial property-tax-based solution was replaced by a funding scheme that relied more heavily on state (as opposed to district) revenue, which has remained in effect, with occasional adjustments, ever since.
Compliance (1983)
In 1983, the Los Angeles County Superior Court found, on remand, that the requirements of Serrano II had been sufficiently met, allowing a relatively small number of residual districts to retain a higher level of funding, based on well-above-average local property taxes.See also
- San Antonio Independent School District v. RodriguezSan Antonio Independent School District v. RodriguezSan Antonio Independent School District v. Rodriguez, 411 U.S. 1 , was a case in which the Supreme Court of the United States held that a school-financing system based on local property taxes was not an unconstitutional violation of the Fourteenth Amendment's equal protection clause...
- California Proposition 13 (1978)California Proposition 13 (1978)Proposition 13 was an amendment of the Constitution of California enacted during 1978, by means of the initiative process. It was approved by California voters on June 6, 1978. It was declared constitutional by the United States Supreme Court in the case of Nordlinger v. Hahn,...
Further reading
- Dollars and Sense: A Simple Approach to School Finance, California Little Hoover CommissionLittle Hoover CommissionThe California Little Hoover Commission , officially the Milton Marks "Little Hoover" Commission on California State Government Organization and Economy, is an independent California state oversight agency modeled after the Hoover Commission and created in 1962, that investigates state government...
, 1997 - Hanushek, Eric A.Eric HanushekEric Alan Hanushek is a Paul and Jean Hanna Senior Fellow at the Hoover Institution of Stanford University. He is also an expert on educational policy. His main area of interest is the economics of education, focusing on controversial areas of education policy including the class size reduction,...
, and Alfred A. Lindseth. 2009. Schoolhouses, courthouses, and statehouses: Solving the funding-achievement puzzle in America's public schools. Princeton, NJ: Princeton University Press
External links
- Text of Serrano I decision via FindLaw
- Text of Serrano II decision via FindLaw
- Text of Serrano III decision via FindLaw