English v. Board of Education
301 F.3d 69 (2002)
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Rule of Law:
The 'one person, one vote' principle, which triggers strict scrutiny, does not apply to a state's legislative scheme that limits representation for non-residents on a local government body when that body exercises only limited, extraterritorial power over them. Such a scheme is subject to rational basis review and is constitutional if it bears some rational relationship to a legitimate state purpose.
Facts:
- The municipality of Lincoln Park educates its high school students by sending them to Boonton High School under a 'send-receive' relationship, for which it pays tuition.
- Lincoln Park students constitute 52% of the student population at Boonton High School.
- The total population of Lincoln Park is 56% of the combined populations of Lincoln Park and Boonton.
- Under New Jersey statute N.J.S.A. § 18A:38-8.2, Lincoln Park is allocated only one representative on the ten-member Boonton Board of Education.
- The Lincoln Park representative's vote is limited to specific matters, such as tuition, capital construction, and certain staffing and curriculum decisions relevant to sending district pupils.
- Lincoln Park maintains and operates its own separate school board and school system for its students in kindergarten through eighth grade.
- The send-receive relationship between Lincoln Park and Boonton can be terminated with the approval of the State's Commissioner of Education.
Procedural Posture:
- Patrick English, a resident of Lincoln Park, filed suit against the Boonton Board of Education and the New Jersey Commissioner of Education in the U.S. District Court for the District of New Jersey.
- The Lincoln Park School Board was permitted to intervene in the lawsuit on behalf of English.
- The parties filed cross-motions for summary judgment in the District Court.
- The District Court granted summary judgment for the plaintiffs, holding that the state statute was unconstitutional as applied to Lincoln Park.
- As a remedy, the District Court ordered an increase in Lincoln Park's representation on the Boonton Board and implemented a vote-weighting system.
- The defendants, the Boonton Board of Education and the Commissioner of Education, appealed the District Court's judgment and remedy to the U.S. Court of Appeals for the Third Circuit.
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Issue:
Does a New Jersey statute that limits a 'sending' school district to one representative on a 'receiving' school district's board, regardless of the sending district's student 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 statute does not violate the 'one person, one vote' principle because the doctrine does not apply to geography-based restrictions on the franchise where a government exercises only limited extraterritorial power. Applying the precedent of Holt v. City of Tuscaloosa, the court reasoned that the 'one person, one vote' principle and its accompanying strict scrutiny standard are not triggered because Lincoln Park residents do not reside within the Boonton School District's geographic boundaries. The Boonton Board's power over Lincoln Park is limited and extraterritorial, as it only controls four of thirteen years of a student's education, and Lincoln Park maintains its own K-8 school board. Because the Boonton Board does not exercise the same level of governmental power over Lincoln Park residents as it does over Boonton residents, the statutory scheme is subject only to rational basis review. The court found the law rational, as the state has a legitimate interest in limiting the influence of a sending district that does not share the same long-term interests as the receiving district and may one day sever the relationship.
Analysis:
This decision clarifies the geographic limits of the 'one person, one vote' doctrine, particularly in the context of inter-governmental agreements. It establishes that a substantial impact on non-residents is not, by itself, sufficient to trigger strict scrutiny for a representation scheme. By applying Holt's rational basis standard to a school board context, the court signals significant judicial deference to state legislatures in structuring cooperative educational arrangements. This ruling narrows the scope for constitutional challenges to such schemes, making it more difficult for sending districts to demand proportional representation unless the receiving district exercises nearly complete governmental control over them.
