Kadrmas v. Dickinson Public Schools

In North Dakota, small school districts could consolidate into larger districts so that the districts could more efficiently educate students in sparsely populated areas. School districts that chose to consolidate were required to submit reorganization plans that set forth how students would be transported to and from school. Dickinson Public Schools (Dickinson) (defendant) had chosen not to reorganize. Until 1973, Dickinson had provided free bus service to students in outlying areas but had required the students to travel to designated pickup points to board the bus. In 1973, Dickinson began offering door-to-door bus service for an annual fee of $97 for one student or $150 for two students. At that time, roughly 13 percent of Dickinson students rode the bus. In 1979, the North Dakota Legislature enacted a statute allowing non-reorganized school districts to charge a fee for transporting students to school as long as the fee did not exceed the district’s cost of providing the bus service. Sarita Kadrmas (plaintiff) was a Dickinson student who lived roughly 16 miles from her school. Until 1985, the Kadrmases had paid the bus fee for Sarita. However, the Kadrmases had a poverty-level income and became unable to pay the fee as their other bills mounted. Sarita and her mother, Paula (plaintiff) brought an action in North Dakota state court to enjoin Dickinson from collecting bus fees, claiming that the fees violated the Equal Protection Clause of the Fourteenth Amendment. The trial court dismissed the action, and the North Dakota Supreme Court affirmed. The United States Supreme Court granted certiorari.