In Martinez v. Bynum (1983) 461 U.S. 321, the court addressed a Texas statute that denied a tuition free public school education to children who lived apart from their parents and had not established that their presence in the school district was not for the primary purpose of attending the public free schools. (Id. at pp. 323-324.) The court determined that it was constitutionally permissible for the state to impose a residency requirement to insure that those attending its schools had the intention of making their home in the district. (Id. at pp. 331-333.) The court held that the state's interests in maintaining the quality of local public schools including proper planning and operation of schools and avoiding overcrowding, fluctuating school populations, and increased school budgets supported imposition of the residence requirements. (Id. at pp. 329-330 & fn. 9.)