Appellant
Della Hadley et al.
Appellee
The Junior College District of Metropolitan Kansas City, Missouri et al.
Appellant's Claim
That the voting rights of a group of junior college district residents were unconstitutionally diluted in violation of the "one man, one vote" principle.
Chief Lawyer for Appellant
Irving Achtenberg
Chief Lawyer for Appellee
William J. Burrell
Justices for the Court
Hugo Lafayette Black (writing for the Court), Harry A. Blackmun, William J. Brennan, Jr., William O. Douglas, Thurgood Marshall, Byron R. White
Justices Dissenting
Warren E. Burger, John Marshall Harlan II, Potter Stewart
Place
Washington, D.C.
Date of Decision
25 February 1969
Decision
The Equal Protection Clause of the Fourteenth Amendment was ruled to apply tothe election of trustees to the junior college district.
Significance
Hadley v. Junior College District clarified the applicability of the "one man, one vote" rule to the election of local government officials.
The appellants in this case were residents of the Kansas City School District, one of eight separate school districts comprising the Junior College District of Metropolitan Kansas City. Under Missouri law, these school districts may vote by referendum to establish a consolidated junior college district andelect six trustees to manage the affairs of that district. When elections under this law resulted in 50 percent of the trustees being chosen from an areacontaining about 60 percent of the total school-age population, a group of residents filed suit, claiming that their right to vote was unconstitutionallydiluted in violation of the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution.
The Lower Court Rulings
A Missouri trial court dismissed the suit. This ruling was then upheld by theMissouri Supreme Court, which held the "one man, one vote" principle did notapply in this case because the trustees had specialized authority over district affairs, rather than general powers of government over the entire district. The state supreme court held that in state or local elections, the Equal Protection Clause requires only that each qualified voter have an equal opportunity to participate in the election, and that election districts must be established on a basis that "as far as practicable will insure that equal numbers of voters can vote for proportionally equal numbers of officials." The casewas appealed to the U.S. Supreme Court.
The Supreme Court Ruling
On 25 February 1970 the U.S. Supreme Court issued its decision. It reversed the ruling of the Missouri Supreme Court, holding that "the Fourteenth Amendment requires that the trustees of the junior college district be apportioned in a manner that does not deprive any voter of his right to have his own votegiven as much weight, as far as is practicable, as that of any other voter inthe junior college district." Justice Black wrote the opinion for the five-justice majority. Justice Harlan wrote a dissenting opinion, on which he was joined by Chief Justice Burger and Justice Stewart. The Court's decision rested on its resolution of two points.
In making its decision, the Court relied on an earlier case, Avery v. Midland County (1968), in which it determined that the Constitution's "one man, one vote" principle applies in local elections where elected officials exercise "general governmental powers over the entire geographic area served bythe body." The Court came to the opposite opinion of the Missouri Supreme Court's, which had ruled that the junior college trustees do not exercise general governmental power over the whole district and are thus immune from the requirements of "one man, one vote":
Apportionment Scheme Ruled Unconstitutional
Next, the Court had to answer the question of whether the apportionment scheme for the elections in this case did in fact violate "one man, one vote." Based upon an examination of the statistical formulas used by the district to determine the make-up of the trustee board, the Court concluded that it did:
In an impassioned dissent, Justice Harlan attacked the decision for, among other things, demonstrating "the pervasiveness of the federal judicial intrusion into state electoral processes that was unleashed by the `one man, one vote' rule of Reynolds v. Sims" (1964). Nevertheless, the majority decision stands as a significant extension of that principal into practically everycorner of American politics.
Related Cases
Della Hadley et al.
Appellee
The Junior College District of Metropolitan Kansas City, Missouri et al.
Appellant's Claim
That the voting rights of a group of junior college district residents were unconstitutionally diluted in violation of the "one man, one vote" principle.
Chief Lawyer for Appellant
Irving Achtenberg
Chief Lawyer for Appellee
William J. Burrell
Justices for the Court
Hugo Lafayette Black (writing for the Court), Harry A. Blackmun, William J. Brennan, Jr., William O. Douglas, Thurgood Marshall, Byron R. White
Justices Dissenting
Warren E. Burger, John Marshall Harlan II, Potter Stewart
Place
Washington, D.C.
Date of Decision
25 February 1969
Decision
The Equal Protection Clause of the Fourteenth Amendment was ruled to apply tothe election of trustees to the junior college district.
Significance
Hadley v. Junior College District clarified the applicability of the "one man, one vote" rule to the election of local government officials.
The appellants in this case were residents of the Kansas City School District, one of eight separate school districts comprising the Junior College District of Metropolitan Kansas City. Under Missouri law, these school districts may vote by referendum to establish a consolidated junior college district andelect six trustees to manage the affairs of that district. When elections under this law resulted in 50 percent of the trustees being chosen from an areacontaining about 60 percent of the total school-age population, a group of residents filed suit, claiming that their right to vote was unconstitutionallydiluted in violation of the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution.
The Lower Court Rulings
A Missouri trial court dismissed the suit. This ruling was then upheld by theMissouri Supreme Court, which held the "one man, one vote" principle did notapply in this case because the trustees had specialized authority over district affairs, rather than general powers of government over the entire district. The state supreme court held that in state or local elections, the Equal Protection Clause requires only that each qualified voter have an equal opportunity to participate in the election, and that election districts must be established on a basis that "as far as practicable will insure that equal numbers of voters can vote for proportionally equal numbers of officials." The casewas appealed to the U.S. Supreme Court.
The Supreme Court Ruling
On 25 February 1970 the U.S. Supreme Court issued its decision. It reversed the ruling of the Missouri Supreme Court, holding that "the Fourteenth Amendment requires that the trustees of the junior college district be apportioned in a manner that does not deprive any voter of his right to have his own votegiven as much weight, as far as is practicable, as that of any other voter inthe junior college district." Justice Black wrote the opinion for the five-justice majority. Justice Harlan wrote a dissenting opinion, on which he was joined by Chief Justice Burger and Justice Stewart. The Court's decision rested on its resolution of two points.
In making its decision, the Court relied on an earlier case, Avery v. Midland County (1968), in which it determined that the Constitution's "one man, one vote" principle applies in local elections where elected officials exercise "general governmental powers over the entire geographic area served bythe body." The Court came to the opposite opinion of the Missouri Supreme Court's, which had ruled that the junior college trustees do not exercise general governmental power over the whole district and are thus immune from the requirements of "one man, one vote":
Appellants in this case argue that the junior college trustees exercised general governmental powers over theentire district and that under Avery the State was thus required to apportion the trustees according to population on an equal basis, as far as practicable. Appellants argue that since the trustees can levy and collect taxes, issue bonds with certain restrictions, hire and fire teachers, make contracts, collect fees, supervise and discipline students, pass on petitions to annex school districts, acquire property by condemnation, and in general managethe operations of the junior college, their powers are equivalent, for apportionment purposes, to those exercised by the county commissioners in Avery. We feel that these powers . . . certainly show that the trustees perform important governmental functions within the districts, and we think these powers are general enough and have sufficient impact throughout the district to justify the conclusion that the principle which we applied in Averyshould also be applied here.
Apportionment Scheme Ruled Unconstitutional
Next, the Court had to answer the question of whether the apportionment scheme for the elections in this case did in fact violate "one man, one vote." Based upon an examination of the statistical formulas used by the district to determine the make-up of the trustee board, the Court concluded that it did:
Although the statutory scheme reflects to some extent a principle of equal voting power, it does so in a way that does not comport with constitutional requirements. This is so because the Act necessarily results in a systematic discrimination against voters in the more populous school districts .. . Consequently Missouri cannot allocate the junior college trustees according to the statutory formula employed in this case.
In an impassioned dissent, Justice Harlan attacked the decision for, among other things, demonstrating "the pervasiveness of the federal judicial intrusion into state electoral processes that was unleashed by the `one man, one vote' rule of Reynolds v. Sims" (1964). Nevertheless, the majority decision stands as a significant extension of that principal into practically everycorner of American politics.
Related Cases
- Gray v. Sanders, 372 U.S. 368 (1963).
- Reynolds v. Sims, 377 U.S. 533 (1964).
- Avery v. Midland Cougraynty, 390 U.S. 474 (1968).
- Karcher v. Daggett, 462 U.S. 725 (1983).
Further Readings
- Biskupic, Joan, and Elder Witt, eds. Congressional Quarterly's Guide to the U.S. Supreme Court, 3rd ed. Washington, DC: Congressional Quarterly, Inc., 1996.
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