Plyler v. Doe

SCOTUSCase
Litigants=Plyler v. Doe
ArgueDate=December 1
ArgueYear=1981
DecideDate=June 15
DecideYear=1982
FullName=James Plyler, Superintendent, Tyler Independent School District, et al. v. John Doe, et al.
USVol=457
USPage=202
Citation=102 S. Ct. 2382; 72 L. Ed. 2d 786; 1982 U.S. LEXIS 124; 50 U.S.L.W. 4650
Prior=Judgment for plaintiffs, 458 F. Supp. 569 (E.D. Texas (1978); affirmed, 628 F.2d 448 (5th Cir. 1980)
Subsequent=Rehearing denied, 458 U.S. 1131 (1982)
Holding=A Texas statute denying free public education to undocumented alien children violated the Equal Protection Clause of the Fourteenth Amendment, because denial on the basis of alienage did not further a substantial state interest. Fifth Circuit Court of Appeals affirmed.
SCOTUS=1981-1986
Majority=Brennan
JoinMajority=Marshall, Blackmun, Powell, Stevens
Concurrence=Marshall
Concurrence2=Blackmun
Concurrence3=Powell
JoinConcurrence3=Brennan, Marshall, Stevens
Dissent=Burger
JoinDissent=White, Rehnquist, O'Connor
LawsApplied=U.S. Const. amend. XIV; Tex. Educ. Code Ann. § 21.031

"Plyler v. Doe", ussc|457|202|1982, was a case in which the Supreme Court of the United States struck down a state statute denying funding for education to children who were illegal immigrants. The Court found that where states limit the rights afforded to people based on their status as aliens, this limitation must be examined under an intermediate scrutiny standard to determine whether it furthers a substantial goal of the State.

ummary

Revisions to education laws in Texas in 1975 withheld state funds for educating children who had not been legally admitted to the United States and authorized local school districts to deny enrollment to such students. A 5-to-4 majority of the Supreme Court found that this policy was in violation of the Fourteenth Amendment, as illegal immigrant children are people "in any ordinary sense of the term", and therefore had protection from discrimination unless a substantial state interest could be shown to justify it.

The court majority found that the Texas law was "directed against children, and impose [d] its discriminatory burden on the basis of a legal characteristic over which children can have little control" — namely, the fact of their having been brought illegally into the United States by their parents. The majority also observed that denying the children in question a proper education would likely contribute to "the creation and perpetuation of a subclass of illiterates within our boundaries, surely adding to the problems and costs of unemployment, welfare, and crime." The majority refused to accept that any substantial state interest would be served by discrimination on this basis, and it struck down the Texas law.

Texas officials had argued that illegal immigrants were not "within the jurisdiction" of the state and could thus not claim protections under the Fourteenth Amendment. The court majority rejected this claim, finding instead that "no plausible distinction with respect to Fourteenth Amendment 'jurisdiction' can be drawn between resident aliens whose entry into the United States was lawful, and resident aliens whose entry was unlawful."

The dissenting minority agreed in principle that it was unwise for illegal alien children to be denied a public education, but the four dissenting justices argued that the Texas law was not so objectionable as to be unconstitutional; that this issue ought to be dealt with through the legislative process; that " [t] he Constitution does not provide a cure for every social ill, nor does it vest judges with a mandate to try to remedy every social problem"; and that the majority was overstepping its bounds by seeking "to do Congress' job for it, compensating for congressional inaction".

This case was decided together with "Texas v. Certain Named and Unnamed Alien Children".

ee also

*List of United States Supreme Court cases, volume 457

References

Further reading

*cite book |chapter="Plyler v. Doe" (1982) and educating children of illegal aliens |title=Latinos and American Law: Landmark Supreme Court Cases |last=Soltero |first=Carlos R. |authorlink= |coauthors= |year=2006 |publisher=University of Texas Press |location=Austin, TX |isbn=0292714114 |pages=118–132

External links

*caselaw source
case="Plyler v. Doe", 457 U.S. 202 (1982)
enfacto=http://www.enfacto.com/case/U.S./457/202/
other_source1=LII
other_url1=http://www.law.cornell.edu/supct/html/historics/USSC_CR_0457_0202_ZO.html
* [http://www.oyez.org/oyez/resource/case/309/ Oyez Case Info]
* [http://federalistblog.us/2008/03/supreme_fraud_plyler_v_doe.html Critical Analysis of Plyler v. Doe]