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.
Appellant citizen, a bachelor who neither owned nor leased taxable real property, filed suit in federal court claiming that N.Y. Educ. Law § 2012 denied him equal protection of the laws in violation of U.S. Const. XIV. The statute limited individuals who were eligible to vote in school district elections to property owners and parents. The district court dismissed the suit, and appellant challenged the decision.
Is a limitation on voter eligibility in a statute to vote on school district elections valid as necessary to promote compelling a state interest?
On appeal, the Court reversed the district court's judgment and remanded the case, finding that N.Y. Educ. Law § 2012 did violate the Constitution. The Court held that § 2012 did not meet the exacting standard of precision required of statutes that selectively distributed the franchise. 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. The classifications must be tailored so that the exclusion of appellant and members of his class is necessary to achieve the articulated state goal. But in this case, the classifications in § 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, thus, violating the equal protection clause.