Kramer v. Union Free School District No. 15

Brief Fact Summary.

The appellant challenged the New York Education Law that provides that residents may vote in the school district election only if they own taxable real property within the district or are parents of children enrolled in the local public schools.

Synopsis of Rule of Law.

If a challenged law grants the right to vote to some bona fide residents of 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.

Facts.

New York Education Law provides that in New York school districts residents may vote in the school district election only if they own taxable real property within the district or are parents of children enrolled in the local public schools. The New York law was challenged but unsuccessfully in the lower court. Appellant was a college-educated stockbroker who lives in his parents’ home.

Issue.

Does the New York law – that require New York residents to either own taxable real property within the district or be parents of children enrolled in the local public schools to be eligible to vote in the school district – violate the Constitution?

Held.

Yes, the State may not limit the exercise of the franchise to those primarily interested or primarily affected. Because New York has failed to demonstrate that the law is necessary to promote a compelling state interest, the New York Education Law is unconstitutional.

Dissent.

Justice Stewart

A State may reasonably assume that its residents have a greater stake in the outcome of elections held within its districts than do other persons and that residents will be more likely to vote responsibly. The majority’s application of strict standard was cannot withstand analysis.

Discussion.

Assuming that New York legitimately might limit the franchise in New York school district elections to those primarily interested in school affairs, the New York Election Law does not meet the exacting standard of precision the Court requires of statutes which selectively distribute the franchise. New York’s classifications include many persons who have a remote and indirect interest in school affairs and exclude others who have a distinct and direct interest in the school meeting decisions.