Hadley v. Junior College District

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 vote given as much weight, as far as is practicable, as that of any other voter in the 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 by the 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 the entire 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 manage the 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 Avery should also be applied here.