Kramer v. Union Free School District No. 15

Facts of the case

Section 2012 of the New York Education Law permitted school districts to limit eligible voters in school district elections to citizens owning or leasing taxable real property and parents of children enrolled in public schools. Union School District No. 15 applied these restrictions. On April 25, 1965, Morris H. Kramer, a resident of district 15 who resided with his parents and had no children, attempted to register for the local school district elections. His application was rejected for failure to comply with the restrictions. Kramer filed a class-action suit against the school board in federal court, claiming his constitutional rights under the Equal Protection Clause of the Fourteenth Amendment had been violated. The district court initially declined to hear his constitutional claims, but, on appeal, the United States Court of Appeals for the Second Circuit directed the district court to hear Kramer's claim. On hearing the complaint, the court found no constitutional violation and denied Kramer's claim.

Question

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

Conclusion

Yes. In a 5-3 decision authored by Chief Justice Earl Warren, the Court accepted Kramer's argument that all district residents share a substantial interest in school meeting decisions. While the statute purported to limit voting rights to those who were "primarily interested" in the election's outcome, the Court found the structure of the law too broad to achieve this goal. The Court concluded that such restrictions must be tailored to achieve the stated goal, and the current classifications "permit inclusion of many persons who have, at best, a remote and indirect interest in school affairs and, on the other hand, exclude others who have a distinct and direct interest in the school meeting decisions."

Supreme Court of the United States

395 U.S. 621, 23 L. Ed. 2d 583, 89 S. Ct. 1886, SCDB 1968-129, 1969 U.S. LEXIS 1261

No. 258

1969-06-16

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