Plyler v. Doe

Following is the case brief for Plyler v. Doe, 457 U.S. 202 (1982).

Case Summary of Plyler v. Doe:

  • A Texas law denied free public education to children who were illegally in the country.  The law was challenged on constitutional grounds in federal court.
  • The Federal District Courts, and the Fifth Circuit Court of Appeals, held that the Texas law violated the Equal Protection Clause of the Fourteenth Amendment.
  • The U.S. Supreme Court agreed.  The Court found the Equal Protection Clause applies to all residents, citizens and aliens alike.  It also found that the importance of educating children (particularly those who are in the country illegally through no fault of their own) outweighs any unsubstantiated desire on the State’s part to save educational resources or mitigate illegal immigration at the border.

Plyler v. Doe Case Brief

Statement of the Facts:

In 1975, the Texas legislature revised its education laws to withhold state funds for the education of children illegally in the country.  It also denied enrollment for such children.  Texas claimed that the revisions were necessary to preserve limited resources for those children residing legally in the State.  It also claimed that the statute would help stem the tide of illegal immigrants coming into the State.

Several lawsuits were filed in two different Federal District Courts, including a class action representing undocumented school-age children of Mexican origin who reside in Texas.  The lawsuits sought a permanent injunction against enforcement of the Texas statute.

Procedural History:

The District Courts in both of the federal lawsuits enjoined enforcement of the law.  The courts held that the Texas law violated the Equal Protection Clause of the Fourteenth Amendment.  The Fifth Circuit Court of Appeals affirmed those decisions.  The U.S. Supreme Court granted certiorari.

Issue and Holding:

Is it a violation of the Equal Protection Clause to deny a free public education to undocumented school-age children?  Yes.

Judgment:

The decision of the Fifth Circuit Court of Appeals is affirmed.

Rule of Law or Legal Principle Applied:

A State’s denial of free public education to undocumented school-age children is a violation of the Equal Protection Clause of the Fourteenth Amendment.

Reasoning:

The Equal Protection Clause provides that no State shall deny “any person within its jurisdiction equal protection of the laws.”  The Clause applies to both citizens and aliens alike.  Accordingly, an undocumented child is a “person” who is “within the jurisdiction” of the State of Texas.  Therefore, that child is entitled to equal protection of the laws of Texas.  It runs counter to the Equal Protection Clause for Texas to provide free public education to children legally in the country, but not those illegally in the country.

Further, education is essential to a person’s life and place in the fabric of society.  Putting undocumented children at an educational disadvantage would be unjust particularly because the children are in the country illegally through no fault of their own.  Finally, employing a rational basis test to evaluate the law, Texas has no rational basis upon which to discriminate in this manner.  No record evidence indicates that excluding undocumented children from school would save Texas any educational resources or have any impact on illegal immigration at the border.

Concurring/Dissenting Opinions:

Concurring Opinion (Marshall):

Because public education holds a unique status in our country, a person’s interest in education is fundamental.  Varying levels of scrutiny should be applied in an equal protection analysis depending upon the significance of the interest adversely affected by particular legislation.

Concurring Opinion (Blackmun):

Denial of an education creates class distinctions which are fundamentally inconsistent with the Equal Protection Clause.  Accordingly, like voting rights cases, strict scrutiny of the Texas law is appropriate because of the fundamental nature of education.

Concurring Opinion (Powell):

It is important to emphasize the unique character of this case.  Undocumented children are being denied an education by virtue of the illegal acts of their parents.  Such a rule invariably results in a permanent underclass of residents that cannot be reconciled with the Equal Protection Clause.  Heightened scrutiny should be applied in this case.

Dissenting Opinion (Burger):

While it would be unwise to create a segment of society made up of illiterate people, the kind of decision here is best left to the democratic process of legislatures.  The Court should not take on the role of setting the Nation’s social policy.

Significance:

Plyler v. Doe established the that a State cannot deny free public education to children who are illegally in the country.  This case also made explicit the notion that the Equal Protection Clause applies to all residents — citizens and aliens alike.  The various opinions of this case grapple with the technical issue of the appropriate level of review with which to evaluate the Texas law.  However, the essence of this case is in the fundamental value of education to our society, and the injustice of denying an education to children solely because their parents came to the country illegally.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/457/202#writing-USSC_CR_0457_0202_ZO

https://www.oyez.org/cases/1981/80-1538

http://www.nytimes.com/1982/06/16/us/justices-rule-states-must-pay-to-educate-illegal-alien-pupils.html

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