Plyler v. Doe
Plyler v. Doe is a significant Supreme Court case decided in 1982 that addressed the rights of undocumented children regarding access to public education. The case arose when Texas revised its laws to allow local school boards to deny enrollment to children whose parents were not legally in the U.S., a policy that disproportionately affected children of Mexican origin. The Court ruled in a 5-4 decision, led by Justice William J. Brennan, Jr., that Texas did not adequately justify this exclusion as a means to serve a substantial state interest. Brennan emphasized that denying educational opportunities to these children would limit their future potential and that the Fourteenth Amendment applies to all individuals within a state’s jurisdiction, regardless of their legal status. This ruling established a precedent that recognized the educational rights of undocumented children but also introduced the concept of intermediate scrutiny, which has implications for future legal challenges concerning public benefits for undocumented individuals. The case remains relevant as discussions about immigration and education rights continue, particularly in light of subsequent legislation and propositions aimed at restricting benefits to undocumented populations.
Plyler v. Doe
Date: June 15, 1982
Citation: 457 U.S. 202
Issue: Alien rights
Significance: The Supreme Court used heightened scrutiny in holding that the denial of educational benefits to the children of undocumented aliens violated the equal protection clause of the Fourteenth Amendment.
In 1975 the state of Texas revised its education laws, encouraging local school boards to deny enrollment of children whose parents had not been legally admitted into the United States. Opponents of the revised policy brought a class-action challenge on behalf of children of Mexican origin who lacked proper documentation. Writing for a 5-4 majority, Justice William J. Brennan, Jr., held that Texas had failed to demonstrate that the exclusion was a rational means for furthering a “substantial state interest.” He argued that the denial of educational opportunity severely restricted the future potentialities of “a discrete class of children not accountable for their disabling status.” The Fourteenth Amendment’s phrase “within its jurisdiction,” according to Brennan, applied “to anyone, citizen or stranger, who is subject to the laws of the state.”
Plyler’s use of intermediate scrutiny rather than strict scrutiny meant that future Supreme Courts would not necessarily strike down all restrictions on public benefits for illegal aliens. The issue became especially controversial when California voters in 1994 adopted Proposition 187, which was designed to eliminate nonemergency benefits for illegal aliens. Congress upheld the measure with the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, while recognizing that the Plyler decision continued to be binding in regard to education.