Students are expected to complete a full legal brief of a U.S. Supreme Court case focusing on a constitutional right or liberty. Each brief will be graded according to the instructions provided in in the GGW textbook (pages 847-848).
To earn the full 10 points for each brief, clearly address the following elements in the case:
Name of the case
Citation of the case
Year of the case
Vote in the case
Factual circumstances of the case
Legal issue or question raised by the case
Outcome of the case
Legal holding of the case
Doctrine announced or applied in the case
Author and legal reasoning of the majority opinion
author and legal reasoning of any concurring opinions (if applicable)
author and legal reasoning of any dissenting opinions (if applicable)
Case Brief #2
Name, Citation, and Year: Kramer v. Union School District No. 15, 395 U.S. 621 (1969)
Vote in the case: 5-3. Only eight justices were confirmed to the Court at the time of the ruling.
Factual circumstances of the case: Appellant, Michael H. Kramer, was a bachelor who lived with his parents within the jurisdiction of Union School District No. 15 in New York State. Section 2012 of the New York Education Law restricted voter eligibility for school district elections in certain school districts to a subsect of voters otherwise eligible to vote in federal and state elections. Those eligible to vote must either own or lease real taxable property within the district, be married to someone who meets the forgoing criteria, or be the custodian or parent of a child enrolled in the district. Meeting none of these criteria, Kramer’s 1965 application to vote in school district elections was denied. Kramer then brought a class action lawsuit against Union School District No. 15 on the basis that Section 2012 violated his right to vote secured by the Equal Protection Clause of the Fourteenth Amendment. After a decision by the Court of Appeals of the Second Circuit required the district court to hear Kramer’s complaint, the U.S. District Court for the Eastern District of New York ruled that Section 2012 was constitutional, and Kramer appealed directly to the U.S. Supreme Court.
Legal issue or question raised by the case: Does Section 2012 of the New York Education Law, and more generally laws that add additional requirements beyond age, citizenship, and residency, violate the Equal Protection Clause of the Fourteenth Amendment?
Outcome of the case: The decision of the district court was reversed, and the case remanded to the lower court for reconsideration in line with the Court’sruling.
Legal holding of the case: Section 2012 of the New York Education Law violates the Equal Protection Clause of the Fourteenth Amendment. All laws adding additional requirements beyond age, citizenship, and residency to voter qualification laws are subject to strict scrutiny and the compelling state interest test.
Doctrine announced or applied in the case: Strict scrutiny of the “Footnote Four” of U.S v. Carolene Products Co., 304 U.S. 144 (1938), requires that a compelling state interest be present in order to unequally burden those exercising the right to vote. The right to vote is sufficiently fundamental to warrant strict scrutiny and is guaranteed by the Equal Protection Clause.
Author and legal reasoning of the majority opinion: Chief Justice Warren. The appellant does not dispute age, citizenship, and residency requirements for state and federal elections, but rather disputes whether or not additional requirements violate the equal protection guaranteed by the Fourteenth Amendment. Reynolds v. Sims, 377 U.S. 533, 562 (1964) held that the right to vote is a prerequisite to our “basic civil and political rights,” and as such, any effective dilution of votes is subject to close scrutiny. McDonald v. Board of Election Commissioners of Chicago¸ 394 U.S. 802 (1969), held that denying the ability to vote is subject to the same close scrutiny. The Court finds first that compelling state interest must be established for the state to be able to grant the right to vote to some while denying it to their equals in age, residency, and citizenship. The ability to elect one’s public officials and legislators cannot be granted on a selective basis without proof of compelling state interest. The Rational Basis Test is insufficient to guarantee equal protection regarding such a fundamental right. Although the voting restrictions of Section 2012 applies where school boards are elected through annual meetings, the fact that the positions could have been filled through appointment is insignificant. It is also insignificant that school boards do not have “general” powers of legislation. What is significant is that under the current law some residents may choose their officials and some may not. Secondly, the Court finds that even if it were the case that the state met the compelling interest standard in its limitation of voting eligibility to “primarily” interested parties, Section 2012 does not adequately or precisely classify voters: some residents who have marginal and indirect interest in the school district can vote while some with clear and direct interest cannot. In this case, the state does not have a compelling interest sufficient to unequally burden the right to vote.
Author and legal reasoning of dissenting opinion: Justice Stewart. In Lassiter v. Northampton Election Bd., 360 U.S. 45 (1959), the Court upheld the constitutionality of literacy requirements in voting, indicating that states have “broad powers” to decide on the conditions of suffrage. Kotch v. Board of River Port Pilot Comm’rs, 330 U.S. 552 (1947) employed a rational basis test as the metric for voter legislation compliance with the Equal Protection Clause. Rational basis was also used in Lassiter, upholding voter legislation that encouraged “intelligent use of the ballot.” Since the groups identified in Section 2012 have a substantial and informed interests in School Board Elections due to property taxation and parental concern, they fulfill this same “intelligent use” criteria. Some outlying responsible voters will be excluded, but the general exclusions of Section 2012 have a rational basis in preventing uninformed voting and simultaneously exercise the legitimate “broad powers” of the legislature. The Court’s application of strict scrutiny is applied in error for three reasons: there is no structural unfairness requiring strict scrutiny because respondent can vote for the legislators who created New York Education Law; voting rights are neither constitutionally protected nor involve racial distinctions; it is inconsistent to allow restrictions based on age, citizenship, and residency while elevating voting rights to strict scrutiny status.
Significance of case for American constitutional development: This case was decided in the context of significant expansion of voting rights during the civil rights movement. The Voting Rights Act of 1965 was passed to ensure that tests that states enacted did not interfere with the right to vote. Reynolds v. Sims (1964) furthered the expansion by declaring the “one person, one vote” doctrine. Kramer is significant in that it elevated the right to vote such that any unequal infringement on this right requires a compelling state interest. This transferred the burden of proof to the state and demanded the state meet an extremely high bar of interest. Kramer would have indirect effects by prompting future decisions to grapple with expansion of strict scrutiny protections, as in San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973).More directly, the need to show compelling state interest in order to unequally deny the vote to citizens of equal classification would frame the ongoing debate over voters rights for years, in cases such as Crawford v. Marion County Election Bd., 553 U.S. 181 (2008).
Significance of case for American constitutional development