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Law School Case Brief

Kramer v. Union Free School Dist. - 395 U.S. 621, 89 S. Ct. 1886, 23 L. Ed. 2d 583, 1969 U.S. LEXIS 1261

Rule:

If a challenged state statute grants the right to vote to some bona fide residents of requisite age and citizenship and denies the franchise to others, the court must determine whether the exclusions are necessary to promote a compelling state interest.

Facts:

The petitioner, Kramer, was refused the right to vote in school district elections, under a New York statute requiring property ownership in the district or children attending district schools to vote in such elections. New York Education Law requires the ownership of real property within a school district or custody of children attending the district to be eligible to vote in school district elections. The petitioner lived with his mother within the school district. His denial of voting rights was based solely on his lack of real property ownership or custody of children. He brought suit, seeking to invalidate the statute as unconstitutional under the Fourteenth Amendment of the United States Constitution.

Issue:

Was the New York statute narrowly tailored to serve a compelling government interest?

Answer:

No.

Conclusion:

The Court held that NY CLS Educ § 2012 did not meet the exacting standard of precision required of statutes that selectively distributed the franchise. The classifications in NY CLS Educ § 2012 permitted inclusion of many persons who had, at best, a remote and indirect interest in school affairs and, on the other hand, excluded others who had a distinct and direct interest in the school meeting decisions. The Court reversed and remanded the district court's order dismissing petitioner's suit challenging the denial of his right to vote in the elections of appellee school district. The Court held that a statute limiting the right to vote in the elections did not meet an exacting standard of precision.

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