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Kadrmas v. Dickinson Public Schools

Supreme Court of the United States · 1988 · Constitutional Law

Constitutional LawEqual ProtectionEqual Protection Clauseschool transportation feesuser feewealth discriminationeducationrational basis

Facts

North Dakota authorized nonreorganized school districts to charge a fee for school-bus service, subject to a statutory cap tied to transportation costs. Dickinson Public Schools, a nonreorganized district, provided door-to-door bus service and charged $97 per year for one child, with fees covering only about 11% of the service's cost. Sarita Kadrmas lived about 16 miles from school, and when her family refused to sign a contract agreeing to pay the fee for the 1985 school year, Dickinson stopped bus service for her. The family then transported Sarita privately at a cost exceeding $1,000 for that year, although she continued to attend school.

Issue

Does the Equal Protection Clause forbid North Dakota from allowing nonreorganized school districts, but not reorganized districts, to charge a fee for transporting public-school students? More specifically, does the statute require heightened scrutiny because it burdens poor families' access to education, or is it valid under rational basis review?

Rule

Unless a statute interferes with a fundamental right or discriminates against a suspect class, it survives equal protection review if the classification is rationally related to a legitimate governmental purpose. Wealth-based disparities alone do not trigger strict or heightened scrutiny, and education is not a fundamental right for this purpose. Social and economic legislation carries a presumption of rationality and will be invalidated only on a clear showing that its classification is arbitrary and irrational.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nebraska authorizes local school districts to charge a capped annual fee for optional late-afternoon activity buses that take students home after clubs and tutoring. The Prairie View District in Lincoln charges $85 to all riders, and several low-income parents argue the fee violates equal protection because poorer families are less able to pay.

How should a court most likely evaluate the parents' equal protection challenge?

Explanation. The governing rule is that, unless a law interferes with a fundamental right or discriminates against a suspect class, it is reviewed under rational basis. The majority held that wealth-based disparities alone do not trigger heightened scrutiny, and education is not a fundamental right for equal protection purposes. A modest user fee for optional transportation therefore receives rational basis review and is likely valid if rationally related to a legitimate governmental purpose.