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.
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.
As long as the election is not one of special interest, any classification restricting the franchise on grounds other than residence, age, and citizenship cannot stand unless the district or State can demonstrate that the classification serves a compelling state interest.View Full Point of Law