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The Equal Protection Clause requires adherence to the principle of one-person, one-vote in elections of state legislators. It is extended to apply to the election of officials of a county government because the elected officials exercise general governmental powers over the entire geographic area served by the body.
The Salt River Project Agricultural Improvement and Power District (District), a governmental entity, stores and delivers untreated water to the owners of 236,000 acres of land in central Arizona, and, to subsidize its water operations, sells electricity to hundreds of thousands of people in an area including a large part of metropolitan Phoenix. Under state law, the system for electing the District's directors limits voting eligibility to landowners and apportions voting power according to the number of acres owned. A class of registered voters living within the District but owning either no land or less than an acre of land there, filed suit, claiming that the election scheme violated the Equal Protection Clause of the Fourteenth Amendment. They alleged that because the District has such governmental powers as the authority to condemn land and sell tax-exempt bonds, and because it sells electricity to virtually half the State's population and exercises significant influence on flood control and environmental management, its policies and actions substantially affect all District residents, regardless of property ownership. The District Court upheld the constitutionality of the voting scheme, but the Court of Appeals reversed. It held that the case was governed by the one-person, one-vote principle established in Reynolds v. Sims, 377 U.S. 533, rather than by the exception to that principle established in Salyer Land Co. v. Tulare Lake Basin Water Storage Dist., 410 U.S. 719, which upheld a state law permitting only landowners to vote for directors of a water district because of its special limited purpose and the disproportionate effect of its activities on landowners as a group.
Does the voting scheme for electing the directors of the District violate the equal protection clause of the Fourteenth Amendment?
The voting scheme established by state law for electing the directors of a water reclamation district which limits voting eligibility to landowners and apportions voting power according to the amount of land each voter owns does not violate the equal protection clause of the Fourteenth Amendment since it bears a reasonable relationship to its statutory objectives, the peculiarly narrow function of the local governmental body and the special relationship of one class of citizens to that body releasing it from the strict demands of the one person, one vote principle, where (1) the district cannot impose ad valorem property taxes or sales taxes, cannot enact any laws governing the conduct of citizens, and does not administer such normal functions of government as the maintenance of streets, the operation of schools, or sanitation, health, or welfare services, (2) all water delivered by the district is distributed according to land ownership, and the district does not and cannot control the use to which the landowners who are entitled to water choose to put it, (3) neither the existence nor the size of the district's electrical power business and the great number of people served by it affects the legality of the property-based voting scheme, and (4) the district's function bears a disproportionate relationship to the specific class of people whom the system makes eligible to vote, the voting landowners being the only residents whose lands are subject to liens to secure district bonds and subject to its acreage-based taxing power and who have ever committed capital to the district through stock assessments.