## Facts

- The City of Sunset Valley was a small general-law municipality located entirely within the Austin Independent School District (AISD) and served by AISD schools.
- Sunset Valley, acting under Texas zoning authority, adopted an ordinance zoning the entire city as residential, excluding nonresidential uses.
- After study and deliberation, AISD’s board determined centralized auxiliary facilities were needed and selected an approximately 62-acre site within Sunset Valley.
- The planned facilities included a football stadium, field house, athletic field, and a bus garage with repair and maintenance facilities, intended to serve multiple district schools rather than a particular campus.
- AISD requested that the City issue a building permit, amend the ordinance, or de-annex the tract; the City refused and threatened to enforce penal provisions if construction began.
- The trial court found AISD’s site selection reasonable; the City did not challenge that finding.
- The trial court granted declaratory and injunctive relief for AISD; the court of civil appeals reversed; the Supreme Court of Texas reversed the appellate court and reinstated the trial court’s judgment.

## Issues

1. Whether a general-law city may use zoning powers to wholly exclude and thereby prevent construction of public school facilities reasonably sited within the city by the independent school district that serves the city.

## Decision

- The Supreme Court of Texas reversed the court of civil appeals and affirmed the trial court’s judgment for AISD.
- The Court held Sunset Valley could not apply its residential-only zoning ordinance to bar AISD’s reasonably located school-related facilities.
- The Court treated the dispute as a conflict between municipal zoning authority and the school district’s legislatively conferred authority to select sites and provide public school facilities.

## Legal Principles

- Texas law assigns school districts and their elected trustees primary responsibility to manage and govern public schools, including authority to select and acquire sites (including by eminent domain), subject to reasonableness.
- A municipality’s general zoning authority does not include, absent clear legislative authorization, power to wholly exclude public school facilities in a manner that conflicts with the school district’s statutory duties.
- Zoning enabling statutes are construed narrowly when a city claims authority that substantially interferes with another governmental entity’s core functions.
- A city may not impose a comprehensive residential zoning scheme to block all public school facilities that a school district has reasonably located within city limits; limited, genuine health-and-safety regulation was not the issue presented.

## Conclusion

Because AISD’s site selection was found reasonable and unchallenged, and because Texas law vests school districts with authority to locate and provide public school facilities, Sunset Valley could not use residential zoning to wholly prevent construction of AISD’s proposed auxiliary facilities within the city.


Austin Indep. Sch. Dist. v. City of Sunset Valley, 502 S.W.2d 670 (Tex. 1973)