Ball v. James

Brief Fact Summary. The Salt River Project Agricultural Improvement and Power District (the District), stores and delivers untreated water to land owners in central Arizona. The directors of the District are voted for by landowners in the district on a one-acre, one-vote system of apportionment.

Synopsis of Rule of Law. In government entities of limited purpose, the State may create voting schemes that are unconstitutional in elections for broader-based entities.

Facts. The District comprises 236,000 acres in central Arizona. As the District’s primary purpose is providing water to these 236,000 acres, the legislature vested the election of the District directors in the hands of the landowners of the District. The landowners’ votes are prorated so that one acre of land owned entitled an individual to one vote.

Issue. Does the voting scheme of the District violate Equal Protection?

Held. No. Justice Potter Stewart (J. Stewart) notes that the narrow and special function of the District justifies a departure from the popular-election requirement. There is a reasonable relationship between the voting system and its governmental objectives.

Dissent. Justice Byron White (J. White) argues that the function of the District is not as narrow as the majority would believe. J. White stresses that the District provides electric power to several hundred thousand citizens and believes that the one-person one-vote principle should apply.

Discussion. The majority and dissent differ only in the characterization of the function of the District. They both agree that if the function is narrow enough, the State voting scheme is acceptable, but if the function is broad, then one-person, one-vote should apply.