Jake Little Thunder v. State of South Dakota

518 F.2d 1253
CourtCourt of Appeals for the Eighth Circuit
DecidedJuly 17, 1975
Docket74-1967
StatusPublished
Cited by27 cases

This text of 518 F.2d 1253 (Jake Little Thunder v. State of South Dakota) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jake Little Thunder v. State of South Dakota, 518 F.2d 1253 (8th Cir. 1975).

Opinion

LAY, Circuit Judge.

Plaintiffs, residents of unorganized counties in South Dakota, brought this class action contending South Dakota law prevented them from voting for county government officials in derogation of their right to equal protection of the law. The district court dismissed their complaint. We reverse and remand for the granting of appropriate injunctive relief.

- The State of South Dakota is divided, by S.D.C.L. §§ 7 — 1—2 through 7 — 1—68 (1967), into sixty-seven county units. For purposes of county administration and government, these sixty-seven counties are divided into organized and unorganized counties. S.D.C.L. § 7-4-1 (1967) recognized the validity of every county government operating as such on the date of South Dakota’s admission as a state. These became the first organized counties. Presumably . all other counties were at that time designated as unorganized counties. A statutory method of organizing a county government, through petition and referendum, was also established and at the present time the only unorganized counties are those in which plaintiffs reside. These three counties are Todd, Washabaugh and Shannon.

Each organized county has a full complement of elected county officials whose task it is to administer the affairs of local government. They include county commissioners, judges, clerk of court, register of deeds, auditor, treasurer, sheriff, coroner and attorney. The unorganized counties, however, do not elect these officials for themselves but rather are attached to an adjoining county for purposes of government and administration. 1 The officials of the organized counties, under the provisions of S.D.C.L. §§ 7-17-3 (1967) and 7-17-5 (1974), administer the affairs of the attached unorganized counties and have all the powers and duties with regard to the attached county that they have in their own. 2 The residents of the unorganized *1255 counties, such as plaintiffs, are not permitted to vote for the county officers in the organized county to which their county is attached. 3 Thus plaintiffs cannot vote for most of the elected county officials who govern them. They may vote only for school board members and highway officials. See S.D.C.L. §§ 12-23-3 and 13-8-1 (1974). They can, of course, vote for all state and national offices.

The state urges this restriction is justified on the premise that a reasonable residency requirement may restrict the right to vote. It contends that, since a majority of the residents of the unorganized counties are reservation Indians, they do not share the same interest in county government as the residents of the organized counties. The state also argues that the unorganized counties can organize at any time and thereby divest the organized county government of power and that this contingency justifies restriction of the franchise. The district court found there existed a rational basis supporting the restriction on plaintiffs’ right to vote. We hold the district court applied the wrong legal standard in assessing the constitutionality of the state’s action and, that there exists under this record no compelling state interest justifying the denial of plaintiffs’ right to vote for their governing officials.

It is fundamental that the states have broad discretion to determine the extent of direct voter participation in local government. Carrington v. Rash, 380 U.S. 89, 91, 85 S.Ct. 775, 13 L.Ed.2d 675 (1965); Pope v. Williams, 193 U.S. 621, 633, 24 S.Ct. 573, 48 L.Ed. 817 (1904). It is equally fundamental that once that extent is determined every citizen has a constitutionally protected right to participate in the electoral process on an equal basis with all other citizens. Dunn v. Blumstein, 405 U.S. 330, 92 S.Ct. 995, 31 L.Ed.2d 274 (1972); Kramer v. Union Free School Dist., 395 U.S. 621, 89 S.Ct. 1886, 23 L.Ed.2d 583 (1969). In an election of general interest, conditions, limitations or restrictions on the franchise, of any character, must meet a stringent test of justification. The Supreme Court has frequently recognized this fact in a variety of situations. Most recently, in Hill v. Stone, 421 U.S. 289, 95 S.Ct. 1637, 44 L.Ed.2d 172 (1975), Mr. Justice Marshall observed:

The basic principle expressed in [Kramer v. Union Free School Dist., 395 U.S. 621, 89 S.Ct. 1886, 23 L.Ed.2d 583 (1969); Cipriano v. City of Houma, 395 U.S. 701, 89 S.Ct. 1897, 23 L.Ed.2d 647 (1969); City of Phoenix v. Kolodziejski, 399 U.S. 204, 90 S.Ct. 1990, 26 L.Ed.2d 523 (1970)] is that as long as the election in question is not one of special interest, any classification restricting the franchise on grounds other than residence, age, and citizenship cannot stand unless the district or State can demonstrate that the classification serves a compelling state interest. (Emphasis added.)

The state urges the limitation is justified since nothing more than a geographic residency requirement is imposed. This view is too simplistic. A state may, of course, impose geographic limits on the franchise, Dunn, supra, 405 *1256 U.S. at 343, 92 S.Ct. 995; Carrington, supra, 380 U.S. at 91, 85 S.Ct. 775, but those limits must bear a close relationship to the underlying interest of the parties affected in the results of the elective process. Geographic residency requirements are permissible when they are designed to insure that only voters who have a substantial interest in the outcome of elections will participate. Evans v. Cornman, 398 U.S. 419, 422, 90 S.Ct. 1752, 26 L.Ed.2d 370 (1970). Here, however, as plaintiffs urge, each of the unorganized counties and the organized county to which it is attached form a single unit of local government

for administration of governmental and fiscal affairs, including all state, county, judicial, taxation, election, recording, canvassing, and foreclosure purposes, excepting in cases where the administration of said affairs is expressly otherwise provided by law. S.D.C.L. § 7-17-1 (1967).

We think it obvious the requirement of residency in the organized county places a special qualification on the right to vote which, in its application to residents of the attached unorganized counties, fails to result from a substantial difference in their interests in the election of county officials.

The decision of the Court in Evans v. Cornman, supra,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Public Integrity Alliance, Inc. v. City of Tucson
805 F.3d 876 (Ninth Circuit, 2015)
Carlson v. Wiggins
760 F. Supp. 2d 811 (S.D. Iowa, 2011)
Large v. Fremont County, Wyo.
709 F. Supp. 2d 1176 (D. Wyoming, 2010)
Shirt v. Hazeltine
336 F. Supp. 2d 976 (D. South Dakota, 2004)
Bd Ed Twp Branchburg v. Livingston
312 F.3d 614 (Third Circuit, 2002)
Board of Education of the Township of Branchburg Gregory Scott Geraldine Feldman Patricia Bowers Robert J. Fulton, Jr., Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Board of Education of the Township of Branchburg Gregory Scott Geraldine Feldman Patricia Bowers Robert J. Fulton, Jr., ( Amended Pursuant to F.R.A.P 43(c)) Board of Education of the Township of Branchburg Gregory Scott Geraldine Feldman Patricia Bowers Robert J. Fulton, Jr., Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey David Livingston William L. Librera, ( Amended Pursuant to F.R.A.P. 43(c)) Board of Education of the Township of Branchburg Gregory Scott Geraldine Feldman Patricia Bowers Robert J. Fulton, Jr., Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey the Board of Education of the Borough of Somerville, ( Amended Pursuant to F.R.A.P 43(c)) Board of Education of the Township of Branchburg Gregory Scott Geraldine Feldman Patricia Bowers Robert J. Fulton, Jr. Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Beth Kovacs Christine Ihling Steven Jankoski, ( Amended Pursuant to F.R.A.P 43(c)) Board of Education of the Township of Branchburg Gregory Scott Geraldine Feldman Patricia Bowers Robert J. Fulton, Jr., Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey Beth Kovacs Christine Ihling Steven Jankoski v. David Livingston, Somerset County Superintendent William L. Librera, State Commissioner of Education the Board of Education of the Borough of Somerville, a Body Politic of the State of New Jersey the Board of Education of the Borough of Somerville, ( Amended Pursuant to F.R.A.P 43(c))
312 F.3d 614 (Third Circuit, 2002)
English v. Board of Education
301 F.3d 69 (Third Circuit, 2002)
United States v. Blaine County, Montana
157 F. Supp. 2d 1145 (D. Montana, 2001)
United States v. Blaine County
157 F. Supp. 2d 1145 (D. Montana, 2001)
Schmidt v. City of Kenosha
571 N.W.2d 892 (Court of Appeals of Wisconsin, 1997)
Kaltsas v. City of North Chicago
513 N.E.2d 438 (Appellate Court of Illinois, 1987)
Buckanaga v. Sisseton Independent School District
804 F.2d 469 (Eighth Circuit, 1986)
St. Louis County, Mo. v. CITY OF TOWN
590 F. Supp. 731 (E.D. Missouri, 1984)
United States v. South Dakota
491 F. Supp. 1349 (D. South Dakota, 1980)

Cite This Page — Counsel Stack

Bluebook (online)
518 F.2d 1253, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jake-little-thunder-v-state-of-south-dakota-ca8-1975.