In 1975, Texas passed a law prohibiting the use of state funds for the education of undocumented children in public schools. In 1977, according to the Library of Congress, “Tyler Independent School District charged $1,000 per year to each child enrolled within the district who did not provide documentation of American citizenship.”
The Mexican American Legal Defense and Educational Fund (MALDEF) brought a class action suit to the district court and, after five years of litigation, the case, Plyler v. Doe, made it’s way to the Supreme Court. On June 15, 1982, in a 5–4 decision, the Supreme Court found that the Texas law violated the Fourteenth Amendment’s Equal Protection Clause and ruled that “all children, regardless of immigration status, have a constitutional right to a free public education from kindergarten to 12th grade.”
Nursery school playground in Robstown camp, Texas, 1942. Photograph by Arthur Rothstein. Source: Library of Congress
A March 2025 article for K–12 Dive notes that challenges to the legal precedent set by Plyler v. Doe have been proposed in Oklahoma, Indiana, Texas, Tennessee, and New Jersey. Another article explains how these “state-level initiatives signal a broader shift in the political and legal landscape surrounding undocumented children’s access to public education.”
Additional Resources
Defending Plyler v. Doe’s Legacy in 2025 by Michelle Embury (Niskanen Center)
Public Education for Immigrant Students: Understanding Plyler v. Doe (American Immigration Council)
Plyler v. Doe by Michael A. Olivas (Texas State Historical Association)
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