Salyer Land Co. v. Tulare Lake Basin Water Storage District
410 U.S. 719 (1973)
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Rule of Law:
The 'one person, one vote' principle established in Reynolds v. Sims does not apply to a special-purpose unit of government, such as a water storage district, whose activities disproportionately affect landowners as a group. A state may rationally limit the franchise to landowners and weight votes according to the assessed value of the land in such districts without violating the Equal Protection Clause.
Facts:
- The Tulare Lake Basin Water Storage District is a special-purpose unit of government in California created to acquire, store, and distribute water for farming.
- The district's population is 77 persons, and four corporations farm 85% of the 193,000 acres of land within its boundaries.
- The district's costs and projects are funded exclusively through assessments against the land within the district, proportionate to the benefits each parcel receives.
- California law governing the district permits only landowners to vote in general elections for the board of directors.
- The same law apportions votes based on the assessed value of the land, giving one vote for each one hundred dollars of land value.
Procedural Posture:
- A group of landowners, a landowner-lessee, and residents (appellants) of the Tulare Lake Basin Water Storage District filed suit against the district (appellee) under 42 U.S.C. § 1983.
- The action was brought before a three-judge federal District Court.
- The appellants sought declaratory and injunctive relief, alleging that California's statutes governing voting in district elections violated the Equal Protection Clause of the Fourteenth Amendment.
- The District Court held that the statutes were constitutional and entered judgment for the water storage district.
- The appellants then filed a direct appeal to the Supreme Court of the United States.
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Issue:
Does California's statutory scheme for water storage district elections, which limits voting to landowners and apportions votes based on the assessed value of their land, violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Rehnquist
No. The California statutory scheme for water storage district elections does not violate the Equal Protection Clause because the district's special limited purpose and the disproportionate effect of its activities on landowners create an exception to the 'one person, one vote' rule. The water storage district lacks the normal powers of government, as its primary purpose is to provide water for agriculture, not to furnish general public services. Since landowners bear the entire financial burden of the district's operations through assessments on their land, the state could rationally conclude that they alone should be responsible for its governance. The vote-weighting scheme is also rational because the benefits and burdens of the district's projects are directly proportional to the assessed value of the land.
Dissenting - Justice Douglas
Yes. The California statutory scheme violates the Equal Protection Clause because the district performs vital governmental functions that substantially affect all residents, not just landowners. The district's flood control activities, for example, have a direct and potentially calamitous impact on non-landowning residents, whose homes and safety are at risk. The scheme disenfranchises nearly all residents and allows a few large corporations, particularly the J. G. Boswell Company, to exercise complete control over the district's board. Weighting votes according to wealth is hostile to democratic principles, and allowing corporations to vote in elections for entities performing governmental functions creates a 'corporate political kingdom' contrary to our constitutional tradition.
Analysis:
This case is significant for establishing the 'special purpose district' exception to the strict 'one person, one vote' requirement of the Equal Protection Clause. By finding that the water district's narrow scope and financial structure justified a departure from traditional democratic principles, the Court created a pathway for states to design voting schemes for limited governmental entities based on property ownership rather than residency. This precedent has been invoked to uphold similar voting structures in other specialized bodies like business improvement districts and agricultural commodity boards. The decision thus distinguishes between general-purpose governments, which must adhere to strict voter equality, and special-purpose entities, where a rational basis for restricting the franchise to those most affected is sufficient.
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