## Facts

- Maryland financed public elementary and secondary schools through a combination of state aid and locally raised revenue by each county and Baltimore City.
- School districts varied widely in taxable wealth, producing different capacities to fund education and to supplement state aid.
- Local boards and taxpayers from property-poor districts alleged that the system resulted in substantially fewer resources than in wealthier districts (e.g., teacher pay, class size, programs, facilities).
- Plaintiffs asserted that wealth-based funding disparities denied students equal educational opportunity.
- The suit challenged the funding statutes under the Maryland Constitution’s education clause (requiring a “thorough and efficient System of Free Public Schools”) and state equal-protection and due-process guarantees.

## Issues

1. Whether the Maryland Constitution makes education a fundamental right requiring strict scrutiny of school-finance disparities under state equal protection.
2. Whether wealth-driven inter-district funding inequalities violate the constitutional command to maintain a “thorough and efficient” statewide system of free public schools.
3. Whether the challenged disparities violate state equal-protection or due-process provisions.

## Decision

- The Court of Appeals of Maryland reversed the trial court’s ruling that the school-finance system was unconstitutional.
- The court held that education is not a fundamental right for Maryland equal-protection analysis; strict scrutiny did not apply.
- The court interpreted the “thorough and efficient” clause as imposing a legislative duty to maintain a statewide public-school system, not to equalize or uniformly fund all districts.
- Applying rational-basis review, the court upheld the combined state-local funding scheme as constitutionally permissible.
- The court rejected due-process and related claims as failing to provide an independent basis for invalidating the statutes.

## Legal Principles

- A right’s importance does not make it “fundamental” for equal-protection purposes absent constitutional text or doctrine requiring heightened scrutiny.
- Maryland’s “thorough and efficient” education clause requires a statewide system providing a basic minimum program and general access, not resource equality among districts.
- Where no fundamental right or suspect class is involved, school-finance classifications are reviewed under rational-basis scrutiny.
- A state may rationally use a mixed state-local school funding model to preserve local control, encourage local fiscal responsibility, and permit communities to choose different spending levels through local taxation.
- Courts generally defer to legislative judgments about allocating limited educational resources when constitutional minima are met.

## Conclusion

Maryland’s highest court sustained the state’s public-school financing statutes, concluding that the constitution requires a statewide free public-school system meeting basic standards but does not mandate inter-district fiscal equalization, and that wealth-based disparities in educational resources are evaluated under rational-basis review rather than strict scrutiny.


Hornbeck v. Somerset Cnty. Bd. of Educ., 458 A.2d 758 (Md. 1983)