Kramer v. Union Free School District No. 15 395 U.S. 621 (1969)

Author:Kenneth L. Karst

Page 1542

New York limited school district VOTING RIGHTS to residents who owned (or leased) real property or were parents (or guardians) of public school children. Following HARPER V. VIRGINIA BOARD OF ELECTIONS (1966), the Supreme Court held, 6?3, that this restriction denied the EQUAL PROTECTION OF THE LAWS to an adult resident living in his parents' home.

Chief Justice EARL WARREN wrote for the Court. ARATIONAL BASIS for the voting limitation was not enough; it must be justified as necessary to promote a COMPELLING STATE INTEREST. Assuming that New York could limit voting to persons especially interested in school affairs, this law's classification was insufficiently tailored to that purpose; an uninterested, non-taxpaying renter could vote, but Kramer, a taxpayer interested in school matters, could not.

The Harper dissenters also dissented here, speaking through Justice POTTER STEWART. The Constitution conferred no right to vote, and no racial classification was involved. Thus there was no reason to heighten judicial scrutiny, and there was a rational basis for limiting...

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