Kramer v. Union Free School District

Brief Fact Summary.

Per New York law, school districts limited eligible voters in school district elections to: 1) citizens owning or leasing taxable real property and 2) parents of children enrolled in public schools. Kramer, who resided with his parents and had no children, attempted to register to vote in the local school district elections. His application was rejected.

Synopsis of Rule of Law.

States may constitutionally limit voting rights only if the law survives strict scrutiny review.

Facts.

Section 2012 of the New York Education Law permitted school districts to limit eligible voters in school district elections to: 1) citizens owning or leasing taxable real property and 2) parents of children enrolled in public schools. Union Free School District applied these restrictions. Kramer, a resident of this school district, who resided with his parents and had no children, attempted to register to vote in the local school district elections. His application was rejected for failure to comply with the restrictions. Kramer brought suit against the school district, claiming his constitutional rights under the Equal Protection Clause of the Fourteenth Amendment had been violated.

Issue.

Did the requirement that Kramer be a landowner or parent of a student in order to vote in school district elections violate his rights under the Equal Protection Clause of the Fourteenth Amendment?

Held.

Yes, the requirement that Kramer be a landowner or parent of a student in order to vote in school district elections violated his rights under the Equal Protection Clause of the Fourteenth Amendment.

Dissent.

Justice Stewart

The statutory classification at issue is clearly valid and democracy is not undermined because Kramer is fully able to participate in the election of representatives of the New York State Legislature, which enacted the voting qualifications at issue.

Short of a doctrinal insistence that universal suffrage is somehow mandated by the Constitution, Kramer’s claim ought to be rejected.

Discussion.

Any unjustified discrimination in determining who may participate in political affairs or in the selection of public officials undermines democracy. Thus, if a statute grants the right to vote to some bona fide residents of a requisite age and citizenship and denies the franchise to others, the Court must determine whether the exclusions are necessary to promote a compelling state interest.

Although the New York statute purports to limit voting rights to those who are “primarily interested” in the election outcome, the law is too broad to achieve this goal. The classification must be tailored so that exclusion of Kramer and members of his class is necessary to achieve the articulated state goal. Section 2012 does not meet this exacting standard of precision because it permits inclusion of many with, at best, a remote interest in school affairs, while excluding others with a distinct interest in the school meeting decisions.