Brief Fact Summary. A single man with no children who lived with his parents challenged a law that required voters in certain school board elections to either own or lease taxable property within that school district, or have children enrolled in the local schools.
Synopsis of Rule of Law. Laws granting the voting franchise to residents on a selective basis always pose the danger of denying some citizens any effective voice in the governmental affairs which substantially affect their lives. Therefore, if a challenged law grants the right to vote to some bona fide residents of the requisite age and citizenship and denies the franchise to others, the Court must determine whether the conclusions are necessary to promote a compelling state interest.
Issue. Whether the New York Education Law’s exclusion is necessary to promote a compelling state interest.
Held. No. Judgment of the lower state courts revered. Assuming that New York might legitimately limit the franchise in these school board elections to those “primarily interested in school affairs,” close scrutiny of the section 2012 classifications demonstrates that they do not accomplish this purpose with sufficient precision to justify denying Appellant the franchise. Its classifications permit inclusions of many persons who have remote and indirect interest in school affairs and exclude others who have a direct and distinct interest in school meeting decisions. Therefore, this law is not necessary to promote a compelling state interest, and thus violates equal protection
In determining whether or not a state law violates the Equal Protection Clause, we must consider the facts and circumstances behind the law, the interests which the State claims to be protecting, and the interests of those who are disadvantaged by the classification.View Full Point of Law