Cunningham v. Municipality of Metropolitan Seattle
1990 U.S. Dist. LEXIS 16614, 751 F.Supp. 885, 1990 WL 197695 (1990)
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Rule of Law:
The 'one person, one vote' principle of the Equal Protection Clause applies to a local government body if it exercises substantial governmental functions and a majority of its members are selected through popular election, even if indirectly by virtue of holding other elected offices, thereby requiring that each qualified voter have an equal opportunity to participate in that election.
Facts:
- The Municipality of Metropolitan Seattle (Metro) is a municipal corporation in King County, Washington.
- Metro is responsible for vital functions including water pollution abatement and public transportation throughout King County.
- Metro was formed in 1958 to address growing regional needs, initially focusing on cleaning up Lake Washington.
- The Metro Council, Metro's governing body, consists of forty-two members.
- The method for selecting Metro Council members is prescribed by Washington state statute RCW § 35.58.120.
- King County, the area served by Metro, has a population of more than 1.4 million residents.
- Voters in King County had previously rejected a proposal to transfer Metro's functions to the county government.
Procedural Posture:
- Registered voters in King County, Washington (plaintiffs), sued the Municipality of Metropolitan Seattle (Metro) and its current chairperson (defendants) in the United States District Court for the Western District of Washington.
- Plaintiffs challenged the constitutionality of the method for selecting the Metro Council, alleging a violation of the 'one person, one vote' principle under the Equal Protection Clause of the Fourteenth Amendment.
- Both plaintiffs and defendants filed motions for summary judgment, agreeing that no genuine issue of material fact existed and the case could be decided on these cross-motions.
- The Attorney General of the State of Washington was granted leave to file an amicus curiae (friend of the court) brief in the case.
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Issue:
Does the method by which the Municipality of Metropolitan Seattle (Metro) Council members are selected violate the one person, one vote principle of the Equal Protection Clause of the Fourteenth Amendment, given that Metro exercises governmental powers and a majority of its members are effectively elected?
Opinions:
Majority - Dwyer, District Judge
Yes, the method of selecting the Metro Council members violates the one person, one vote principle of the Equal Protection Clause because Metro exercises substantial governmental powers and a majority of its members are effectively chosen by popular election, leading to impermissibly disproportionate representation. The court first determined that Metro possesses broad governmental powers. Metro operates a county-wide mass transit system and a sewage system for over 1.4 million residents. It is statutorily granted legislative, financial, and police powers, including the authority to levy sales taxes and excise taxes (with voter approval), issue bonds, condemn property, set rates and charges, and adopt rules with penalties. These extensive powers, which have a significant impact on all King County residents, prevent Metro from qualifying for the 'narrow functions' exception established in Salyer Land Co. v. Tulare Lake Basin Water Storage Dist. Second, the court analyzed whether the Metro Council is an 'elected body.' Of the forty-two members, twenty-four are deemed elected because they automatically become Metro Council members upon election to other county or city positions. These include the King County Executive, the mayors of five large cities, all nine King County Council members, and all nine Seattle City Council members. Applying the precedent from Board of Estimate v. Morris, the court found that since these individuals assume Metro Council seats 'as a matter of law upon their various elections,' they are considered popularly elected members. The remaining eighteen members are appointed through various selection processes by other officials or bodies. Because a majority (24 out of 42) of the Council members are elected, the Metro Council is subject to the one person, one vote principle. Finally, the court concluded that the current selection method results in an unconstitutional level of disproportionate representation. In calculating deviations, only elected members are counted, as the aim is to protect voters' rights in choosing representatives. Based on the 24 elected members and King County’s population, the ideal voter-to-representative ratio is 60,250:1. The calculation revealed a maximum deviation of 196.47% between the most over-represented and most under-represented areas. This deviation far exceeds the 78% found unconstitutional in Board of Estimate and cannot be justified by arguments of efficiency, historical practice, or group interests, as established in Reynolds v. Sims. Therefore, the current system violates the Equal Protection Clause.
Analysis:
This case significantly clarifies the application of the 'one person, one vote' doctrine to hybrid governmental bodies whose members are not directly elected to that specific body but gain seats automatically upon election to other offices. It firmly rejects arguments that efficiency or historical practices can justify a denial of equal protection in voting rights. The decision also establishes a clear methodology for calculating representational deviations in bodies with both elected and appointed members, specifically by excluding appointed members from the calculation, thereby ensuring that the focus remains on the efficacy of individual votes.
