involving unenumerated rights, the Court's "task...should be to determine the extent to which constitutionally guaranteed rights are dependent on interests not mentioned in the Constitution," and "[a]s the nexus between the specific constitutional guarantee and the nonconstitutional interest draws closer, the nonconstitutional interest becomes more fundamental and the degree of judicial scrutiny applied when the interest is infringed on a discriminatory basis must be adjusted accordingly." Reaction and aftermath In a 2015 TIME interview of over 50 legal scholars, University of California, Berkeley Law School Dean Erwin Chemerinsky and Cornell Law Professor Steven Shiffrin both named Rodriguez the "worst Supreme Court decision since 1960," with Chemerinsky noting that the decision has "played a major role in creating the separate and unequal schools that exist today." Partially in response to the Court's ruling in Rodriguez, Justice William Brennan wrote an article in the Harvard Law Review urging lawyers and litigants to turn to their State Supreme Courts — rather than the U.S. Supreme Court — to litigate their constitutional claims, as the conservative Burger Court would likely be unreceptive to claims made by racial minorities, the poor, or other "politically powerless groups whose members have historically been subjected to purposeful discrimination." Since Brennan's article was published, a number of State Supreme Courts have held that substantially unequal public school funding violates their State Constitutions. In April 2020 a three judge panel of the United States Sixth District Court of Appeals voted 2–1 in Gary B. v. Whitmer to recognize that children have a US constitutional right to basic literacy education. The panel decision distinguished San Antonio Independent School District v. Rodriguez, which did not address the fundamental right to basic education. After an appeal for an en banc review, the case was settled and the panel's precedential decision vacated. See also Abbott District, a legal doctrine in New Jersey state constitutional law resulting from a series of cases holding that the education of children in certain poor, urban communities was unconstitutionally inadequate. Edgewood Independent School District v. Kirby, a 1993 Texas decision recognizing that unequal funding of public school districts violated the Texas State Constitution. Roosevelt Elementary School Dist. v. Bishop, a 1994 Arizona Supreme Court decision holding that substantially unequal school funding violates the Arizona Constitution. Serrano v. Priest, a post-Rodriguez decision in which California courts found that the method of funding schools violated the California Constitution's equal protection clause.