Why This Matters
Texas Supreme Court cases—along with landmark U.S. Supreme Court rulings originating in Texas—reveal how courts shape public policy on education, civil rights, and federalism. You're being tested on more than just case names and dates; exams want you to understand judicial review, equal protection, state constitutional requirements, and the ongoing tension between state and federal authority. These cases demonstrate how litigation becomes a tool for policy change when legislatures fail to act.
When studying these cases, focus on the legal principles each one established and how they connect to broader themes in Texas government: the structure of the court system, the relationship between state and federal courts, and the role of the Texas Constitution in shaping policy. Don't just memorize outcomes—know what constitutional provision or legal doctrine each case interprets and why that matters for governance today.
School Finance and the Texas Constitution
The Texas Constitution requires a "general diffusion of knowledge," which has made school funding a recurring battleground in state courts. These cases illustrate how judicial interpretation of state constitutional language can force legislative action—or, in some instances, defer to legislative discretion.
Edgewood Independent School District v. Kirby (1989)
- Landmark ruling on school finance equity—the Texas Supreme Court found the state's funding system unconstitutional because wealthy districts could tax at lower rates yet generate more revenue than poor districts
- "General diffusion of knowledge" clause became the constitutional standard for evaluating whether the legislature met its educational obligations under Article VII
- Triggered the "Robin Hood" plan, which redistributed property tax revenue from wealthy to poor districts and remains controversial in Texas politics today
Neeley v. West Orange-Cove Consolidated Independent School District (2005)
- Found the finance system unconstitutional again—this time because local property taxes had effectively become a statewide tax without legislative authorization
- Distinguished between equity and adequacy, ruling that even if funding were distributed fairly, the total amount might still be constitutionally insufficient
- Forced legislative action on school finance reform, demonstrating how courts can mandate policy change even when they cannot dictate specific solutions
Morath v. The Texas Taxpayer and Student Fairness Coalition (2016)
- Upheld the existing school finance system—the court found it met minimum constitutional requirements despite acknowledged flaws and inequities
- Applied a deferential standard of review, signaling that courts would not micromanage legislative funding decisions as long as basic constitutional thresholds were met
- Closed (temporarily) decades of litigation, though debates about adequacy and equity in Texas education funding continue
Compare: Edgewood v. Kirby vs. Morath v. Texas Taxpayer—both addressed school finance under the same constitutional provision, but Edgewood struck down the system while Morath upheld it. The difference? Courts grew more deferential to legislative judgment over time. If an FRQ asks about judicial restraint vs. activism in Texas, these cases make an excellent contrast.
Civil Rights and Federal Constitutional Claims
Several landmark cases originated in Texas but were decided by the U.S. Supreme Court under federal constitutional provisions. These illustrate federalism in action—when state laws conflict with federal constitutional protections, federal courts have the final word.
Sweatt v. Painter (1950)
- Challenged "separate but equal" in higher education—Heman Sweatt sued after being denied admission to the University of Texas Law School solely because of his race
- U.S. Supreme Court ruled the separate Black law school was inherently unequal, considering factors like faculty reputation, alumni networks, and prestige that couldn't be replicated
- Precursor to Brown v. Board of Education, establishing that intangible factors matter in equal protection analysis and weakening the legal foundation of segregation
Plyler v. Doe (1982)
- Struck down Texas law denying public education to undocumented children—the U.S. Supreme Court found this violated the Equal Protection Clause of the Fourteenth Amendment
- Education recognized as uniquely important, even though it's not a "fundamental right"—the Court applied heightened scrutiny because denying education creates a permanent underclass
- Established that undocumented persons are "persons" under the Fourteenth Amendment and cannot be denied equal protection without substantial justification
Lawrence v. Texas (2003)
- Invalidated Texas sodomy laws—the U.S. Supreme Court ruled that criminalizing private, consensual same-sex conduct violated the Due Process Clause's protection of liberty
- Overturned Bowers v. Hardwick (1986), marking a major shift in constitutional interpretation regarding privacy and intimate relationships
- Foundation for later LGBTQ+ rights decisions, including Obergefell v. Hodges (2015), which legalized same-sex marriage nationwide
Compare: Sweatt v. Painter vs. Plyler v. Doe—both used equal protection analysis to expand rights for marginalized groups in Texas, but Sweatt focused on race while Plyler addressed immigration status. Both demonstrate how federal courts can override state policies that violate constitutional guarantees.
Voting Rights and Redistricting
Redistricting cases reveal the tension between legislative discretion in drawing district lines and federal protections for minority voting rights under the Voting Rights Act. These cases show how courts balance competing interests in the political process.
Richards v. League of United Latin American Citizens (2001)
- Challenged Texas redistricting for diluting Latino voting power—the court found that the legislature's plan failed to adequately protect minority representation as required by federal law
- Applied Voting Rights Act Section 2, which prohibits voting practices that discriminate based on race or ethnicity, even without proof of intentional discrimination
- Resulted in redrawn districts to ensure Latino voters had fair opportunities to elect representatives of their choice
San Antonio Independent School District v. Rodriguez (1973)
- U.S. Supreme Court ruled education is NOT a fundamental right under the federal Constitution, allowing Texas's unequal school funding system to stand
- Applied rational basis review, the most deferential standard, finding that the state had legitimate reasons for its property-tax-based funding system
- Pushed reform efforts to state courts, since the federal Constitution offered no remedy—this is why Edgewood v. Kirby was litigated under the Texas Constitution instead
Compare: Rodriguez vs. Edgewood v. Kirby—both challenged Texas school finance, but Rodriguez failed in federal court while Edgewood succeeded in state court. This perfectly illustrates why state constitutions matter: they can provide broader protections than the U.S. Constitution. Exam tip: if asked about federalism and education policy, this pairing is essential.
Jurisdiction and Corporate Law
Texas courts also shape business law and jurisdictional questions, determining when out-of-state corporations can be sued in Texas courts.
In re Nestle USA, Inc. (2012)
- Established jurisdictional standards for foreign corporations—the Texas Supreme Court ruled that Texas courts could exercise jurisdiction over Nestle based on its business contacts with the state
- Applied "minimum contacts" doctrine, requiring that a corporation have sufficient ties to Texas before being subject to its courts
- Set precedent for corporate litigation in Texas, clarifying when businesses can be held accountable in state courts for their actions
Emerging Legal Questions
Some Texas cases address novel legal issues that don't fit neatly into traditional categories but raise important questions about rights and property.
Davis v. Davis (1992)
- Addressed the legal status of frozen embryos in divorce—the Texas Supreme Court treated embryos as property subject to division rather than as persons with independent rights
- Balanced reproductive autonomy interests, recognizing that both parties had legitimate but potentially conflicting claims to the embryos
- Raised unresolved questions about reproductive rights, biotechnology, and family law that continue to evolve as technology advances
Quick Reference Table
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| School Finance (Texas Constitution) | Edgewood v. Kirby, Neeley v. West Orange-Cove, Morath v. Texas Taxpayer |
| Equal Protection (Federal) | Sweatt v. Painter, Plyler v. Doe, Rodriguez |
| Privacy/Liberty Rights | Lawrence v. Texas |
| Voting Rights/Redistricting | Richards v. LULAC |
| State vs. Federal Courts | Rodriguez (federal) vs. Edgewood (state) |
| Judicial Review Power | Edgewood v. Kirby, Neeley v. West Orange-Cove |
| Desegregation | Sweatt v. Painter |
| Corporate Jurisdiction | In re Nestle USA |
Self-Check Questions
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Which two school finance cases reached opposite conclusions despite addressing similar constitutional questions, and what explains the different outcomes?
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Why did plaintiffs challenging Texas school funding succeed in Edgewood v. Kirby (state court) after failing in San Antonio v. Rodriguez (federal court)?
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Compare Sweatt v. Painter and Plyler v. Doe: what constitutional provision did both cases rely on, and how did each expand civil rights protections?
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If an FRQ asks you to explain how Texas courts can force legislative action, which case would best illustrate judicial review under the Texas Constitution? What remedy did the court impose?
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How does Lawrence v. Texas demonstrate the relationship between state criminal law and federal constitutional protections? What earlier precedent did it overturn?