Ball v. James

451 U.S. 355 (1981)

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Nature of the Case

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Facts

This lawsuit was brought by a class of registered voters who live within the geographic boundaries of the District and who own either no land or less than an acre of land within the District. Seeking declaratory and injunctive relief, the appellees claimed that the acreage-based scheme for electing directors of the District violates the Equal Protection Clause of the Fourteenth Amendment. On cross-motions for summary judgment and stipulated facts, the District Court for the District of Arizona held the District voting scheme constitutional and dismissed the complaint. A divided panel of the Court of Appeals for the Ninth Circuit reversed. Noting this Court's repeated application of the one-person, one-vote principle established in Reynolds v. Sims, 377 U.S. 533, the Court of Appeals turned its attention to the case in which this Court marked a significant exception to that principle by upholding a state law permitting only landowners to vote in the election of directors of a water district: Salyer Land Co. v. Tulare Lake Basin Water Storage District, 410 U.S. 719. The decision in Salyer resulted from this Court's examination of the nature of the services provided by the water district in that case, and its conclusion that, 'by reason of its special limited purpose and of the disproportionate effect of its activities on landowners as a group,' the water district there was not subject to the strict one-person, one-vote demands of the Reynolds decision. The court concluded that the Salt River District does not serve the sort of special, narrow purpose that proved decisive in Salyer. The Court of Appeals found it significant that all the general obligation bonds have so far been serviced out of the District's electricity revenues, and that all capital improvements have been financed by revenue bonds, which have been issued in the amount of $600 million, and which are junior to the general obligation bonds. The court thus concluded that the actual financial burden of running the District has not fallen primarily on the voting landowners, and therefore that the activities of this water district, unlike those of the district in Salyer, do not disproportionately affect landowners as such.