Law School Case Brief
Salyer Land Co. v. Tulare Lake Basin Water Storage Dist. - 410 U.S. 719, 93 S. Ct. 1224 (1973)
A water storage district, by reason of its special limited purpose and of the disproportionate effect of its activities on landowners as a group, is the sort of exception to the "one person, one vote" rule laid down in Reynolds, which Hadley and Avery contemplated.
Appellants, who were landowners, a landowner-lessee, and residents in a California water storage district, brought this action under 42 U.S.C.S. § 1938 against appellee Tulare Lake Basin Water Storage District. They sought declaratory and injunctive relief in an effort to prevent the water district from giving effect to certain provisions of the California Water Code. They contended that Cal. Water Code §§ 41000 and 41001 unconstitutionally denyied them equal protection of the laws by permitting only landowners to vote in district general elections and by apportioning votes in the elections according to the assessed valuation of the land. The District Court upheld the validity of the statutes.
Were certain provisions of California Water Code violative of the Equal Protection Clause by permitting only landowners to vote in district general elections and by apportioning votes in the elections according to the assessed valuation of the land?
On appeal, the Supreme Court of the United States held that the voting pattern was rationally based because the benefits and burdens to each landowner were in proportion to the assessed value. Small landowners were protected from crippling assessments because both a majority of the votes and a majority of the voters approved a given measure. About 189 landowners, who were small landowners, constituted a majority. The lessees were not without remedy for their disenfranchised state because the lessees could bargain for the right to vote at the time of lease negotiation; therefore, the exclusion of the lessees did not violate the Equal Protection Clause. Because the landowners as a class were to bear the entire burden of the district's costs, the state could rationally conclude that the landowners should be responsible for the district's operation, thereby dispensing with the litigants' Equal Protection Clause argument. Affirming the judgment, the Court concluded that because the voter qualification statutes for California water storage district elections were rationally based, they therefore did not violate the Equal Protection Clause.
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