Kramer v. Union Free School District No. 15
395 U.S. 621 (1969)
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Rule of Law:
When a state statute grants the right to vote to some residents while denying it to others, the exclusions must be necessary to promote a compelling state interest and must be narrowly tailored to achieve that purpose.
Facts:
- New York Education Law § 2012 restricted voting in certain school district elections to residents who either (1) owned or leased taxable real property within the district, or (2) were parents or guardians of children enrolled in the local public schools.
- Morris Kramer was a 31-year-old, college-educated stockbroker who lived in the Union Free School District No. 15, a district where § 2012 applied.
- Kramer was a bachelor with no children.
- Kramer lived in his parents' home and neither owned nor leased taxable real property within the school district.
- Kramer met all other state voting requirements, including age, citizenship, and residency, and had voted in state and federal elections.
- In 1965, the school district rejected Kramer's application to register for and vote in the local school district elections because he failed to meet either the property or parental requirements.
Procedural Posture:
- Kramer filed a class-action lawsuit in the U.S. District Court for the Eastern District of New York, challenging the constitutionality of the state law.
- The single-judge District Court initially dismissed Kramer's complaint.
- Kramer, as appellant, appealed to the U.S. Court of Appeals for the Second Circuit.
- The Second Circuit reversed, ruling that a three-judge district court should be convened to hear the constitutional challenge.
- On remand, the three-judge District Court was convened and ruled against Kramer, finding § 2012 constitutional and dismissing the complaint.
- Kramer then filed a direct appeal to the Supreme Court of the United States.
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Issue:
Does New York Education Law § 2012, which limits the franchise in certain school district elections to residents who own or lease real property or are parents of children enrolled in the local public schools, violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Chief Justice Warren
Yes, the New York law violates the Equal Protection Clause of the Fourteenth Amendment. Statutes that deny the franchise to some citizens while granting it to others must be subjected to strict scrutiny and are unconstitutional unless the state can show the exclusions are necessary to promote a compelling state interest. New York argued its goal was to limit the franchise to those 'primarily interested' in school affairs. However, the classifications in § 2012 are not sufficiently tailored to achieve this goal; they are both overinclusive, by enfranchising some residents with only a remote interest, and underinclusive, by disenfranchising others with a direct and substantial interest in school matters. Because the law is not drawn with the precision required for statutes that infringe on the fundamental right to vote, it fails this exacting standard of review.
Dissenting - Justice Stewart
No, the New York law does not violate the Equal Protection Clause. The traditional rational basis test, not strict scrutiny, should apply because this is a limited, special-purpose election, not a general one. The State of New York has broad power to determine voting conditions, and it is entirely rational to conclude that local educational policy is best determined by those with a direct interest: parents of schoolchildren and local property taxpayers who fund the schools. The classification is reasonably related to a legitimate state purpose. The majority's application of strict scrutiny is inappropriate because the law was passed by a state legislature in which the appellant has full voting rights, meaning the structure of government is not inherently unfair to him.
Analysis:
This case is significant for applying the strict scrutiny standard of review to statutes that create classifications for voter eligibility, solidifying the right to vote as a fundamental right under the Equal Protection Clause. By rejecting the 'rational basis' test for such laws, the Court made it substantially more difficult for states to disenfranchise specific groups of residents in any election, general or special-purpose. The decision requires that any such classification must not only serve a compelling interest but also be narrowly tailored, a high bar that protects against both overinclusive and underinclusive voter qualifications.
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