Brief Fact Summary. The Petitioner, Kramer (Petitioner), was refused the right to vote in school district elections, under a New York statute requiring property ownership in the district or children attending district schools to vote in such elections.
Synopsis of Rule of Law. Statutes limiting the right to vote must be narrowly tailored to achieve a compelling state interest.
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
Issue. Is the New York statute narrowly tailored to serve a compelling government interest?
Held. No. Appeals Court ruling reversed. Chief Justice Earl Warren (J. Warren) notes that the State’s legitimate interest seems to be restricting a voice in school matters to those “directly affected.” J. Warren notes that the system of exclusion excludes some members that have a direct interest (individuals whose children are not yet school age) and includes some with little interest (individuals with no children who just incidentally own real property in the district). As such, it cannot be narrowly tailored.
Dissent. Justice Potter Stewart (J. Stewart) argues that the classification is valid, as the State has “broad powers to determine the conditions under which the right to suffrage may be exercised.” As the classification in the present case is not of a suspect class, J. Stewart argues that the classification is constitutional.
Discussion. The right to vote is a fundamental right. Notice that J. Warren does not say that the State cannot discriminate as to who gets to vote in a school district election, only that such discrimination must be tailored to the compelling interest sought to be advanced.