Earl Panior and William M. Johnson, on Behalf of Themselves and All Others Similarly Situated v. The Iberville Parish School Board, Etc.

498 F.2d 1232
CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 13, 1974
Docket73-2797
StatusPublished
Cited by13 cases

This text of 498 F.2d 1232 (Earl Panior and William M. Johnson, on Behalf of Themselves and All Others Similarly Situated v. The Iberville Parish School Board, Etc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Earl Panior and William M. Johnson, on Behalf of Themselves and All Others Similarly Situated v. The Iberville Parish School Board, Etc., 498 F.2d 1232 (5th Cir. 1974).

Opinions

JOHN R. BROWN, Chief Judge:

The District Court approved a reapportionment plan for electing members to the Iberville Parish School Board (Board). The plan’s operation results in (i) two districts being over-represented by over 21%, two under-represented by over 15% — a total deviation of 37.-45%, and (ii) several incumbents (elected under the previous, concededly malapportioned ward system) being automatically continued in office. Appellants, self described as a class of under-represented black residents of Iberville Parish, claim the new plan violates their federal constitutional rights to fair representation. We agree.

The Board first complains appellants should have pursued a remedy in the Louisiana courts, under the state reapportionment statute. (See note 1, infra). But that ignores the function of the Fourteenth Amendment which secures the equal protection of minorities’ rights from the inequalities imposed upon them by state laws. In particular, this includes not only every citizen’s right to vote, but the right to have that vote count as much as any other voter’s. Reynolds v. Sims, 1964, 377 U.S. 533, 84 S.Ct. 1362, 12 L.Ed.2d 506.

[1234]*1234The Board, presumably responding to the laudable recent statute1 requiring equality in Louisiana School Board elections, adopted the challenged 15-district representation plan to replace an earlier state legislatively imposed 9-ward system which had disparities running as high as 48% under and 42% over representation. In contrast to the previous ward plan, the new districts are claimed to have been designed to conform to the four elementary-to-high school sub-systems existing in four “eommunities-ofinterest”, (i) Maringouin, Rosedale, and Grosse Tete, (ii) Metropolitan Plaque-mine, (iii) White Castle, and (iv) a two-district area on the “other” (East2) side of the Mississippi River.

At the outset there is the question of whether the governmental responsibilities and operations of the Parish School Board call for the one-man-one-vote standard. On argument the Court called for additional briefs. We are of the clear view that the principle applies. Under Louisiana law the Board has the power to determine the number of schools to be operated by the parish and their location, to employ and discharge all employees of the school system including teachers and principals, to fix salaries of all employees, to purchase property and equipment and to construct schools, to lease and sell school system property, and to assign students to the various schools. See, La.R.S. 17:81-17:87, 17:104, 17:443.3

These responsibilities and activities are the substantial equivalent of the governmental operations declared to be [1235]*1235adequate in Hadley v. Junior College District, 1970, 397 U.S. 50, 90 S.Ct. 791, 25 L.Ed.2d 45.4

Relying on Hadley, federal courts have consistently held elected state boards of education and local school boards bound by the “one person, one vote” standard. Powers v. Maine School Administration District, No. 1, D.Me., 1973, 359 F.Supp. 30 (district board); LoFrisco v. Schaffer, D.Conn., 1972, 341 F.Supp. 743 (local board), summarily aff’d, 1972, 409 U.S. 972, 93 S.Ct. 313, 34 L.Ed.2d 236; Leopold v. Young, D. Vt., 1972, 340 F.Supp. 1014 (district board); Dameron v. Tangipahoa Parish Police Jury, E.D.La., 1970, 315 F.Supp. 137 (Parish school board); Fahey v. Lexalt, D.Nev., 1970, 313 F.Supp. 417 (state board). See also, Dundee v. Orleans Parish Board of Supervisors of Elections et al., 5 Cir., 1970, 434 F.2d 135. And we do not regard subsequent Supreme Court cases dealing with specialized situations as significantly undermining Hadley or its holding.5

When it comes to the merits the Board wholly failed to supply a record justification for the 37.45% deviation from numerical equality among the 15 new districts.6 And in assaying the initial arithmetical achievement of the ideal the deviation is the total of the extreme over-representation and the extreme under-representation (see Dist. A and B as under-represented and Dist. I and J as over-represented. App., infra). Indeed, this seems to have been the source of the trial Judge’s mis judgment on the extent of the disparity and hence, the need for corrective action. For in a number of ways he was positive that the deviation began with zero either up or down, but not both. But in this world of constitutional numbers the test lays the voting strengh of the most disadvantaged voter against that of the most overprivileged. Mahan v. Howell, 1973, 410 U.S. 315, 93 S.Ct. 979, 35 L.Ed.2d 320; Abate v. Mundt, 1971, 403 U.S. 182, 91 S.Ct. 1904, 29 L.Ed.2d 399.

The principal factor urged by the Board is the existence of the four so-called communities of interest. Complicating, but a part of that, is the geographical separation of the area on the East Bank of the River. We do not doubt that, as in many essentially rural parishes throughout the state or in counties throughout the land, there are here the four pretty well definable groupings, clusters of people, with the natural commercial and social activities flowing from these concentrations. But these facts do not justify the marked deviation in the election of this body.

There is first the fact of history. In the thirty some years in which the highly disparate 9-ward plan was in effect the school system operated without any indicated difficulty through a 9-man Board elected from ward lines bearing no conscious relationship to the four communities of interest.

When it came time to reapportion as the 1970 law required, the Board acted commendably in seeking the assistance of the staff of the Louisiana School Board Association and the Public Affairs Research Council (PAR). Eleven plans were submitted by PAR and the 15-man plan adopted was substantially a [1236]*1236joint product of the Board and PAR. But in laying down guideline criteria to PAR for development of a plan other than those eleven, the Board representatives stressed finding lines which would best assure reelection of the incumbents.7 And considering that PAR was sought out for its familiarity with the problem of reapportionment of Louisiana governmental units and thereby had a non-legal working knowledge of Supreme Court cases on factors and percentages, it is significant that its Director of Research (see note 7, supra) stated that PAR would not have recommended the 15-man plan adopted.

And all these possible subjective motivations aside, the most important thing is the statutory structure of the Board, its duties and responsibilities. (See note 3, supra). The Board acts as a unit. The Board as a whole has the responsibility for operating all of the schools. The Board’s function and responsibility is not decentralized into the four segments. Granted that it is both understandable and permissible that election lines may be drawn to take into account centers of interest, this cannot justify deviations approaching those here for election to an operative body which has to act as a unit.

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Bluebook (online)
498 F.2d 1232, Counsel Stack Legal Research, https://law.counselstack.com/opinion/earl-panior-and-william-m-johnson-on-behalf-of-themselves-and-all-others-ca5-1974.