Salyer v. Tulare

This case helped to establish the precedent that on certain occasions, it is constitutionally correct for states to set laws regarding environment, even if it restricts the right for all people to vote.

In general, the Equal Protection Clause of the Fourteenth Amendment protects an individual's right to vote. Sometimes, when certain segments of the population have been denied the right to vote, the U.S. Supreme Court has deemed these restrictions or exclusions unconstitutional under the Equal Protection Clause.

However, the Equal Protection Clause does not mean that just because a state law seems to differentiate between different segments of society, there has been a constitutional violation. Rigorous, strict standards have been established to resolve whether the underlying motives behind a statute are prejudicial or helpful in nature. Each case must stand on its own merits. The courts must examine each case's facts and particular circumstances to balance a state's claims of protecting a certain group's interests with the actual interests of the excluded group.

In California, as in other western U.S. areas, different seasons of the year can mean major differences in water availability. Early spring can swell rivers and streams with runoff from melting snow in high mountains. Later in the year, the water can literally dry up. This is why there are so many water storage facilities and dams in these areas. The larger and more populated areas require larger and more expensive projects funded by state and federal resources.

However, many projects are smaller. They may affect a smaller area of land or a more sparsely populated area. In California, the legislature created a number of ways to respond locally to water-related issues. One such measure was the creation of water storage districts. These districts have the power to plan and execute approved water-related projects having to do with acquiring, conserving and distributing water. They can apply tolls and water-use charges, collecting them from everybody who benefits from their water or related services, in proportion to the received services. A board of directors governs each district. Each division within the district elects one director. The elections are in odd-numbered years. These elections are at the heart of Salyer v. Tulare.

At the time, 77 people lived in the Tulare Lake Basin Water Storage District. Most of these people worked for one of the four corporations that farmed about 85 percent of Tulare's 193,000 acres. The case was instituted by Tulare Lake District landowners, a land-owner lessee and non-land owning district residents. They alleged that two sections of the California Water Code--41000 and 41001--denied voting rights to them guaranteed through the Fourteenth Amendment's Equal Protection Clause.

Section 41000 says that only titled landowners can vote in general elections. Section 41001 states that qualified voters can vote in any precinct in which they own land and they can cast one vote for every $100.00 "or fraction thereof, worth of his land, exclusive of improvements, minerals, and mineral rights therein, in the precinct." So, to vote one had to own land and the allotment of votes depended on how much land was owned. Residents who were not landowners felt they had been disenfranchised by not being allowed to vote and the smaller landowners felt that the votes were too heavily weighted for the larger landowners.

The plaintiffs submitted their case to the three-judge district court which ruled, by majority, that both of the California Water statutes fell within the limits of the Equal Protection Clause. At this point, the Salyer Land Company appealed to the U.S. Supreme Court. The Supreme Court heard the case and in a 6-3 decision, affirmed the district court's ruling.

Based on the circumstances of this particular case, Justice Rehnquist's majority opinion took into account such considerations as the district's limited function and the disproportionate effect of actions on the large landowners.

In his dissenting opinion, Justice Douglas quoted the Supreme Court in the matter of Reynolds v. Sims:

Legislators represent people, not trees or acres. Legislators are elected by voters, not farms or cities or economic interests. As long as ours is a representative form of government, and our legislatures are those instruments of government elected directly by and directly representative of the people, the right to elect legislators in a free and unimpaired fashion is a bedrock of our political system.

Furthermore, said Justice Douglas:

One corporation can outvote 77 individuals in this district. Four corporations can exercise these governmental power as they choose, leaving every individual inhabitant with a weak, ineffectual voice. The result is a corporate political kingdom undreamed of by those who wrote our constitution.