On October, 21, 2011, U.S. District Judge C. Lynwood Smith Jr. dismissed Lynch v. Alabama, ruling that Alabama’s property-tax system does not deny equal-protection to black and low-income students under the fourteenth amendment to the federal constitution. The case, filed in March of 2008, was brought by children and parents in Lawrence and Sumter counties who alleged under-funding of the state’s K-12 public school system, particularly in rural and majority black schools, based on clauses of the Constitution that were written after reconstruction with the specific intent of limiting funding for schools attended by black children.
Plaintiffs claimed that these tax rates have lasting effects on Alabama’s children and disproportionately impact Alabama’s black and low-income children, particularly in the Black Belt region in the state.
Judge Smith said that “Plaintiffs have proved a disparity in funding among the state’s public schools systems, but not a disparity along racial lines.” He concluded that the amendments adopted in the 1970’s and 1980’s to Alabama’s 1901 Constitution allow and encourage “a large measure of participation in and control of each district’s schools at the local level.”
Because Smith held that recent tax code amendments did not have clear racial discriminatory intent and that the provisions do not produce a racially disproportionate effect, Alabama’s tax code was subject to a “rational basis” standard of judicial review. This review resulted in a ruling in favor of the defendants.
Though the court did not rule that the tax bill or its implementation discriminated against black or low-income students under the equal protection clause of the federal constitution, Smith noted the inability of rural counties, in the Black Belt and elsewhere, to generate local tax revenues to fund public services to the extent of urban counties:
“The children of the rural poor, whether black or white, are left to struggle as best as they can in underfunded, dilapidated schools. Their resulting lack of an adequate education not only deprives those students of a fair opportunity to prepare themselves to compete in a global economy, but also deprives the State of fully-participating, well-educated adult citizens.”