## Facts

- Multiple property-poor Texas school districts, parents, and students challenged the State’s public-school finance system under the Texas Constitution.
- Texas funded public education through combined state, local, and federal sources; local districts relied primarily on ad valorem property taxes.
- Wide variation in taxable property wealth among districts produced large disparities in per-student revenue and educational resources.
- Property-poor districts could tax at higher rates yet raise substantially less per pupil than property-rich districts taxing at lower rates.
- Plaintiffs alleged these disparities impaired educational opportunity (e.g., teacher quality, facilities, curriculum, and instructional equipment).
- After a bench trial, the district court held the system unconstitutional under the education clause and certain individual-rights provisions; the court of appeals reversed.

## Issues

1. Whether Texas’s school-finance system, heavily dependent on local property taxes and producing major wealth-based disparities, satisfied the duty to maintain an “efficient system of public free schools” under Tex. Const. art. VII, § 1.
2. Whether the same system violated the Texas Constitution’s equal-rights and due-course-of-law provisions (Tex. Const. art. I, §§ 3, 19).

## Decision

- The Supreme Court of Texas reversed the court of appeals and, with modification, affirmed the trial court’s judgment that the finance system was unconstitutional.
- The Court held the system violated Tex. Const. art. VII, § 1 because it was not “efficient” in light of extreme wealth-driven disparities in access to educational funding and opportunity.
- The Court emphasized that crafting a constitutional replacement system was the Legislature’s responsibility and remanded for legislative action consistent with the constitutional standard.

## Legal Principles

- The education clause (Tex. Const. art. VII, § 1) imposes an affirmative duty on the Legislature to provide and maintain an “efficient” statewide system of public free schools.
- “Efficient” is not limited to administrative or fiscal economy; it requires a structure that provides substantially equal access to similar revenues for education at similar levels of local tax effort.
- A finance system that ties educational opportunity to local property wealth—so that districts with comparable tax effort have materially unequal revenue-raising capacity—fails the constitutional efficiency requirement.
- Courts may declare a school-finance system unconstitutional and articulate the governing constitutional standard, but the design of the remedial funding structure is primarily for the Legislature.

## Conclusion

The Texas Supreme Court invalidated Texas’s public-school finance system because reliance on local property wealth produced major, tax-effort-linked disparities in educational funding and opportunity, violating the constitutional requirement of an “efficient system of public free schools,” and it directed the Legislature to enact a constitutionally compliant system.


Edgewood Indep. Sch. Dist. v. Kirby, 777 S.W.2d 391 (Tex. 1989)