Plyler v. Doe

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Plyler v. Doe
Supreme Court of the United States
Argued December 1, 1981 Decided June 15, 1982
Full case name: James Plyler, Superintendent, Tyler Independent School District, et al. v. John Doe, et al. Citations: 457 U.S. 202; 102 S. Ct. 2382; 72 L. Ed. 2d 786; 1982 U.S. LEXIS 124; 50 U.S.L.W. 4650 Prior history: Judgment for plaintiffs, 458 F. Supp. 569 (E.D. Texas (1978); affirmed, 628 F.2d 448 (5th Cir. 1980) Subsequent history: 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.
Court membership
Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Jr., Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor
Case opinions
Majority by: Brennan Joined by: Marshall, Blackmun, Powell, Stevens Concurrence by: Marshall Concurrence by: Blackmun Concurrence by: Powell Joined by: Brennan, Marshall, Stevens Dissent by: Burger Joined by: White, Rehnquist, O'Connor
Laws applied
U.S. Const. amend. XIV; Tex. Educ. Code Ann. § 21.031

Plyler v. Doe, 457 U.S. 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.

Contents 1 Summary 1.1 Implication for illegal immigration 2 See also 3 External links 4 References

[edit] Summary

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 undocumented 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.

[edit] Implication for illegal immigration

In United States v. Verdugo-Urquidez, the Supreme Court specifically referenced Plyler v. Doe and stated

those cases in which aliens have been determined to enjoy certain constitutional rights establish only that aliens receive such protections when they have come within the territory of, and have developed substantial connections with, this country.^[1]

[edit] See also

• List of United States Supreme Court cases, volume 457

[edit] External links

• Oyez Case Info
• Supreme Court Decision - Syllabus of 457 U.S. 202, Plyler v. Doe
• Supreme Court Decision - Opinion of 457 U.S. 202, Plyler v. Doe

[edit] References