Holt Civic Club v. Tuscaloosa - 439 U.S. 60, 99 S. Ct. 383 (1978)

Rule:

The Fourteenth Amendment does not prohibit legislation merely because it is special, or limited, in its application to a particular geographical or political subdivision of the state. Rather, the Equal Protection Clause is offended only if the statute's classification rests on grounds wholly irrelevant to the achievement of the state's objective.

Facts:

Ala. Code § 11-40-10 (1975) provided that the police jurisdiction of large cities extended three miles beyond the municipal boundaries. Those subject to jurisdiction under § 11-40-10 could not vote in the city, but were only assessed license fees at half the rate of city residents. The plaintiffs, a civic organization and certain residents of Holt, Alabama, an unincorporated community located within the police jurisdiction of Tuscaloosa, contended that the city's exercise of police powers over Holt residents, without extending the right to vote in city elections to such residents, violated the equal protection and due process clauses of the Fourteenth Amendment. Rejecting the plaintiffs' constitutional claims, a three-judge District Court dismissed the action. Plaintiffs appealed.

Issue:

Did Ala. Code § 11-40-10 (1975) violate the equal protection and due process clauses of the Fourteenth Amendment?

Answer:

No.

Conclusion:

The Court held that Ala. Code § 11-40-10 (1975), the police jurisdiction statute, had a rational relationship to a legitimate state purpose because the state had a legitimate interest in seeing that citizens in outlying areas had police services. Moreover, the Court held that a compelling state interest was not required to justify the denial of the voting franchise to residents of the police jurisdiction area, there being no constitutional requirement that extraterritorial extension of the franchise must accompany extraterritorial extension of municipal powers, and it being consistent with equal protection requirements for a government unit to restrict the right to participate in its political processes to those who reside within its borders. Because the outlying non-residents were not residents of the city, they had no right to vote in the city. Therefore, the due process and equal protection claims of the outlying non-residents and the civic association failed.