Martinez v. Bynum: The Court’s Ruling
The sister appealed to the Supreme Court, which deemed it necessary to define two major components of the Texas statute. The first of these components was the issue of whether Roberto lived apart from a parent or guardian. Roberto’s sister claimed that her “custody” of Roberto for five years was sufficient to meet the requirement of parent or guardian. However, the Court determined that the wording of the statute deliberately intended that in order to establish residency, a child was required to live with his or her natural parents or with guardians; guardians were defined as persons appointed by the courts or those having lawful control over children with the responsibility to care for their rights and needs. The Court reasoned that while the sister had cared for her brother, her custody did not rise to the level of parenthood or guardianship.
In reviewing the second component of the statute, concerning the need to be present in a district to obtain an education, the Supreme Court pointed out that history revealed that board officials had been liberal in allowing students to attend school without benefit of a parent or guardian if they resided in the district for any reason other than to obtain an education. The Court acknowledged that while the board had, on occasion, granted tuition-free admission to children who were in the district without benefit of a parent or guardian, the state of Texas (and the McAllen School District) was within its rights to deny a tuition-free education to students who lived in the school district solely to receive a free American education.
Additionally, the Supreme Court was of the opinion that because a public education is not a right guaranteed to individuals by the Constitution, bona fide residence requirements that are clearly defined and uniformly applied further a state’s interest in meeting constitutional standards. The Court concluded both that the statute that denied a tuition-free education to students who lived in a school district without parents or a guardian and whose sole purpose was to obtain an education satisfied constitutional standards and that the board was not required to provide tuition-free education.