English v. Board of Educ. of Town of Boonton
301 F.3d 69 (2002)
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Rule of Law:
A state may legitimately restrict voting rights in local elections to residents within a governmental unit's geographic borders, even when that unit exercises significant extraterritorial power over non-residents. The 'one person, one vote' principle does not apply unless the governmental unit exercises a level of control over non-residents that is substantially equivalent to the control it exercises over its own residents.
Facts:
- The municipality of Lincoln Park, New Jersey, does not operate its own high school.
- For over 50 years, Lincoln Park has maintained a 'send-receive' relationship with the neighboring town of Boonton, sending its high school students to Boonton High School.
- Lincoln Park pays tuition to the Boonton School District for its students, based on the actual cost per student.
- For the 2001-02 school year, students from Lincoln Park constituted 52% of the student body at Boonton High School.
- The total population of Lincoln Park was 56% of the combined populations of Lincoln Park and Boonton.
- Under New Jersey statute N.J.S.A. § 18A:38-8.2, because Lincoln Park's students comprise more than 10% of the high school's enrollment, it is entitled to appoint only one representative to the ten-member Boonton Board of Education.
- The Lincoln Park representative's vote on the Boonton Board is statutorily limited to specific issues, such as tuition, capital construction used by sending pupils, and relevant staffing and programs.
Procedural Posture:
- Patrick English, a resident of Lincoln Park, filed suit against the Board of Education of the Town of Boonton and the New Jersey Commissioner of Education in the U.S. District Court for the District of New Jersey.
- The Lincoln Park Board of Education was permitted to intervene on behalf of English.
- The plaintiffs alleged the state's representation statute, as applied, violated the Equal Protection Clause.
- On cross-motions for summary judgment, the District Court granted summary judgment in favor of English.
- The District Court declared the statute unconstitutional as applied and ordered a remedial plan increasing Lincoln Park's representation and implementing a weighted voting system.
- The Boonton Board of Education and the Commissioner of Education, the defendants, appealed the District Court's judgment to the U.S. Court of Appeals for the Third Circuit.
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Issue:
Does a state law that limits a 'sending' school district to one representative on a 'receiving' school district's board of education, even when the sending district's students constitute a majority of the relevant school population, violate the 'one person, one vote' principle of the Fourteenth Amendment's Equal Protection Clause?
Opinions:
Majority - Becker, Chief Judge
No. The New Jersey law allocating one representative to Lincoln Park on the Boonton Board of Education does not violate the 'one person, one vote' principle. The Supreme Court's decision in Holt Civic Club v. City of Tuscaloosa permits geographically-based restrictions on the franchise, even when a governmental unit exercises 'extraterritorial' powers. Strict scrutiny does not apply because the Boonton Board does not exercise a level of control over Lincoln Park residents that is equivalent to its control over Boonton residents; Boonton only governs four of thirteen years of a Lincoln Park student's education, and Lincoln Park maintains its own K-8 school board. Since the relationship can be severed, Lincoln Park residents do not share the same long-term interests as Boonton residents. Therefore, the statute is subject only to rational basis review, which it survives because the state has a legitimate interest in preserving the receiving district's control over its own district-wide and long-term affairs.
Analysis:
This decision reinforces the principle established in Holt Civic Club that geographic boundaries are a legitimate basis for restricting the franchise, even when non-residents are significantly impacted by a government's decisions. The court sets a high bar for extending voting rights to non-residents, requiring a showing that the government exercises nearly identical powers over them as it does over residents. This ruling signals significant judicial deference to state legislatures in structuring local government and education policy, limiting federal court intervention in complex inter-local agreements so long as a rational basis for the arrangement exists.
