In 1982, the U.S. Supreme Court ruled in Plyler v. Doe that all school-age children, regardless of immigration status, were entitled to a free public education. The ruling struck down a 1975 Texas law that let school districts deny enrollment to undocumented children or charge them tuition. A new study by FutureEd Research Advisor Stella Flores at Boston College and Mehdi Akhbari, Julia Mena Bernal, and Lesley Rivas at the University of Texas at Austin found that within two years of the ruling, the Latino share of Texas K-12 students jumped from 25 percent to 40 percent, while other states saw little to no change in the proportion of Latino students in their schools over the same period. The study’s findings suggest that if the Supreme Court were to overturn Plyler, as the Trump administration has proposed, public school enrollments could decline significantly in states with substantial Latino populations.
Texas was the only state with a law explicitly allowing schools to restrict enrollment for undocumented children, so researchers compared it to states without such a policy. Despite differences in K-12 student composition, Texas and the comparison states experienced similar pre-1982 growth in Latino student enrollment, enabling the researchers to isolate the impact of the Plyler decision on Texas school enrollment. Researchers drew on the Civil Rights Data Collection, which tracks school-level enrollment by race, and the American Community Survey, which collects information on individual demographics, place of birth, citizenship status, and school enrollment. Because the data doesn’t record immigration status explicitly, researchers used foreign-born, non-citizen Hispanic children as a proxy for children likely to be undocumented. They also focused on those aged 12 or younger in 1982 who were most likely to have been excluded under the Texas law.
The Plyler v. Doe ruling was associated with Latino enrollment increases in both datasets. School-level data show that Latino share of enrollment in Texas spiked by 15 percentage points between 1982 and 1984, the two years immediately following the ruling, while Latino enrollment in comparison states stayed relatively flat. The individual-level survey data, which only allows a decade-long comparison, tells a similar story for foreign-born, non-citizen children: enrollment for this group rose by roughly 8.5 percent more in Texas than in other states between 1980 and 1990. The gains were most pronounced among the youngest children, with enrollment increasing by about 30 percent among five-year-olds—suggesting the ruling mostly helped children start school at the typical age, rather than bringing older kids back.
To understand the mechanisms behind these gains, the researchers analyzed several student subgroups. Because the ruling eliminated tuition barriers, they examined whether lower-income families saw larger increases. While lower-income households did show higher rates of enrollment, the difference was not statistically significant, which the authors attribute to a small sample size.
The enrollment surges were also heavily concentrated by country of origin. Children born in Mexico saw a 10 percent increase in enrollment, while children born elsewhere showed no significant change. This pattern aligns with historical demographics, as Mexico was the primary country of origin for undocumented immigrants in Texas at the time.
Because federal databases do not explicitly record immigration status, the researchers had to rely on demographic proxies, making the results suggestive rather than definitive. Still, they argue that demonstrating Plyler v. Doe‘s effects on enrollment carries new weight given the ruling is now being challenged again by at least five states, including Texas. The Supreme Court’s original decision warned that excluding children from school would create an underclass of uneducated residents, harming both civic and economic welfare. The authors similarly conclude that denying students the right to public schooling based on their immigration status would likely have profound effects on the nation’s future workforce.
