Ball v. James
451 U.S. 355 (1981)
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Rule of Law:
A special-purpose governmental entity whose functions disproportionately affect a specific class of citizens is not subject to the strict one-person, one-vote requirement of the Equal Protection Clause, even if its operations are large-scale and also affect the general public.
Facts:
- In the early 20th century, the Salt River Project was formed under the Reclamation Act of 1902 to provide irrigation water for farmers in central Arizona.
- Initially, a private entity, the Salt River Valley Water Users Association, was created, with voting rights and financial assessments based on the number of acres each member owned.
- In 1937, to gain the ability to issue tax-exempt bonds, the Salt River Project Agricultural Improvement and Power District was formed as a public, political subdivision of Arizona.
- The Arizona legislature specifically amended state law to allow this new public district to retain the acreage-based voting system of the original private association.
- The District's primary and originating purpose is the storage, conservation, and delivery of water to owners of the 236,000 acres of land within its boundaries.
- To subsidize its water operations, the District began generating and selling hydroelectric power, eventually becoming a major electricity supplier to hundreds of thousands of people, including many non-landowners in metropolitan Phoenix.
- The District's general obligation bonds are secured by liens on the land within the district, subjecting only landowners to this financial risk.
- While approximately 40% of the water delivered by the District is for non-agricultural uses, entitlement to all water is based on land ownership.
Procedural Posture:
- A class of registered voters owning little or no land within the Salt River Project Agricultural Improvement and Power District sued the District in the U.S. District Court for the District of Arizona.
- The plaintiffs sought a declaratory judgment that the District's acreage-based voting scheme violated the Equal Protection Clause of the Fourteenth Amendment.
- The District Court granted summary judgment in favor of the District, holding the voting scheme was constitutional.
- The plaintiffs, as appellants, appealed to the U.S. Court of Appeals for the Ninth Circuit.
- A divided panel of the Ninth Circuit reversed the District Court, finding the voting scheme unconstitutional.
- The District, as appellant, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the voting system of a water reclamation district, which limits voting eligibility to landowners and apportions votes based on acreage, violate the Equal Protection Clause of the Fourteenth Amendment when the district is also a major provider of electricity to the general public?
Opinions:
Majority - Justice Stewart
No, the acreage-based voting system does not violate the Equal Protection Clause. The one-person, one-vote principle established in Reynolds v. Sims does not apply because the Salt River District falls under the exception carved out in Salyer Land Co. v. Tulare Lake Basin Water Storage District. The District meets the Salyer test because it has a 'special limited purpose'—water storage and delivery—and its activities have a 'disproportionate effect' on landowners. The District does not exercise general governmental powers like imposing ad valorem taxes, enacting laws, or running schools. Its massive electricity business is merely incidental to its primary purpose of subsidizing water costs for landowners. The landowners are uniquely burdened as their lands are subject to liens securing the District's bonds and are liable for acreage-based taxes, making their relationship to the District fundamentally different from that of a mere electricity consumer. Therefore, the voting scheme bears a reasonable relationship to its statutory objectives and is constitutional.
Dissenting - Justice White
Yes, the voting system violates the Equal Protection Clause. The majority misapplies the narrow Salyer exception by characterizing the District's function as 'peculiarly narrow.' The District is a massive municipal corporation that exercises substantial governmental powers, including eminent domain, issuing tax-exempt bonds, and setting electricity rates for hundreds of thousands of consumers without public oversight. The financial burden of the District's operations has shifted from landowners to the general public, as 98% of its revenues derive from electricity sales, effectively creating a subsidy for landowners. The impact on non-voting residents who pay for power is substantial, not incidental. This case is far more analogous to cases where property-based voting for municipal utilities was struck down, and thus the strict one-person, one-vote standard should apply.
Concurring - Justice Powell
No, the voting scheme is constitutional, primarily because the Arizona Legislature, which is elected according to the one-person, one-vote principle, has the authority to create and modify the District's structure. The District does not exercise core sovereign powers typical of general-purpose governments. Federal courts should defer to state legislatures to experiment with political structures for managing local resources. The people of Arizona, through their elected representatives, remain the ultimate authority and can reform the District's governance as political and demographic needs change, a process which should be allowed to operate without judicial interference.
Analysis:
This decision significantly expands the Salyer exception to the one-person, one-vote rule, demonstrating that even a massive, quasi-utility serving a large urban population can be classified as a 'special-purpose' district. The ruling reinforces the distinction between entities with general governmental powers and those with limited functions, even when those 'limited' functions have an enormous economic impact on the public. It gives states greater latitude to create special districts with non-majoritarian, property-based voting schemes, so long as the district's legal purpose remains narrow and a disproportionate risk or burden can be tied to the enfranchised class.
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