Stewart v. Parish School Board of the Parish of St. Charles

310 F. Supp. 1172, 1970 U.S. Dist. LEXIS 12733
CourtDistrict Court, E.D. Louisiana
DecidedFebruary 25, 1970
DocketCiv. A. 69-2818
StatusPublished
Cited by34 cases

This text of 310 F. Supp. 1172 (Stewart v. Parish School Board of the Parish of St. Charles) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stewart v. Parish School Board of the Parish of St. Charles, 310 F. Supp. 1172, 1970 U.S. Dist. LEXIS 12733 (E.D. La. 1970).

Opinion

WISDOM, Circuit Judge:

This case involves the right to vote in a school bond election.

Louisiana laws, unlike the laws of thirty-six states, restrict eligibility to vote in bond elections to qualified voters who are “property taxpayers”. 1 In *1173 such elections the affluence of the voter is made the electoral standard by a requirement no other State imposes on the electorate: Political subdivisions in Louisiana may issue bonds only if they are approved by a “majority in number and amount of the property” of the taxpayers who vote in the election. 2 These laws deny the vote to parents, lessees, and others who have a direct and substantial stake in public education generally and in the proposition put to a vote, but by necessity or choice do not own real estate in the political subdivision where the election is held. 3 By gearing the weight of each elector’s vote to the amount of his assessed property the laws debase the vote of small landowners. We hold therefore that the exclusion of all non-property taxpayers and the dilution of the small property holder’s vote violate the Equal Protection Clause of • the Fourteenth Amendment.

The parties have stipulated the facts and have agreed to submit the case to the Court to be “disposed of on the matter of the issuance of a permanent injunction, the parties waiving their respective interests to a hearing on a temporary injunction”.

The St. Charles Parish School Board on September 23, 1969, conducted a special election to decide whether the Parish School Board should be authorized to issue bonds to the amount of $5,250,000 for capital acquisition and improvement of public schools in the parish. 4 There *1174 are 10,275 registered voters in the Parish; 7808 are white and 2421 are Negro voters. The election was hard fought, perhaps because residents on one side of the Mississippi River were at odds with residents on the other side of the River. 5 (All of the plaintiffs reside on the East bank.) Despite the public interest in the election, only 2,385 electors voted. 6 The official tabulation showed that 1,271 voters, representing an assessed valuation of $1,650,168.50, voted in favor of authorizing the bond issue; 1,114 voters, representing an assessed valuation of $1,261,310, voted against the bond issue. The bond issue was approved therefore by a majority of 157 votes in number presumably representing an assessed valuation of $388,858.30.

The plaintiffs brought this action on November 21, 1969, against the Parish School Board and School District No. 1, the sole and parish-wide school district in St. Charles Parish, to set aside the election and to enjoin the defendants from offering or selling the bonds.

The plaintiffs fall into two classes: (1) non-property taxpayers, who were ineligible to vote and (2) property taxpayers, who were eligible to vote but whose assessments were less than the assessments of others who voted in the election. In each class some of the plaintiffs have children enrolled in the public schools in St. Charles Parish; some do not.

I.

Certain principles involving voting rights apply to elections across the board. The one man, one vote canon of Reynolds v. Sims, 1964, 377 U.S. 533, 84 5. Ct. 1362, 12 L.Ed.2d 506, is such a principle: it bars dilution of the franchise. Avery v. Midland County, 1968, 390 U.S. 474, 88 S.Ct. 1114, 20 L.Ed.2d 45, extends the Reynolds v. Sims canon to subdivisions of a state including, of course, school districts. In Harper v. Virginia State Board of Elections, 1966, 383 U.S. 663, 86 S.Ct. 1079, 16 L.Ed.2d 169, the Court, striking down the poll tax, concluded: “[Sjtate law violates the Equal Protection Clause * * * whenever it makes the affluence of the voter or payment of any fee an electoral standard. Voter qualifications have no relation to wealth nor to paying or not paying this or any other tax! * * * Wealth, like race, creed, or color, is not germane to one’s ability to participate intelligently in the electoral process. Lines drawn on the basis of wealth or property, like those of race * * * are traditionally disfavored.” These three decisions are basic to our conclusions in this case.

*1175 II.

Two recent decisions of the Supreme Court control this case: Kramer v. Union Free School District, 1969, 395 U.S. 621, 89 S.Ct. 1886, 23 L.Ed.2d 583, and Cipriano v. City of Houma, 1969, 395 U. S. 701, 89 S.Ct. 1897, 23 L.Ed.2d 647.

In Kramer the Court considered a New York statute limiting the vote in local school board elections to parents and guardians of children attending public schools in the district and to residents who owned or leased taxable real property. The defendants contended that parents and guardians constituted a group “primarily” interested in school affairs, an interest not shared by the public generally. In Kramer, as in the case before this Court, the School District and the State contended that property owners and lessees of taxable property had a special interest in decisions affecting public schools, since the funds for such schools were derived almost entirely from the taxes paid on real property. The three-judge district court held that restricting voting to these two groups was “rational” and “within the limits of the State’s power to fix” qualifications for voting. The court characterized the election of a school board as a special purpose election, distinguishing Harper which involved a general election. 282 F.Supp. 70 (E.D.N.Y.1968), on remand from 379 F.2d 491 (2nd Cir. 1967).

The Supreme Court, in a five to three opinion by Chief Justice Warren, held that the voting qualifications denied equal protection to the excluded voters. The Court pointed out, quoting from Reynolds v. Sims, that state statutory and constitutional provisions prohibiting the exercise of the voting franchise to some electors, while allowing it to others, must be “carefully and meticulously scrutinized” 7 to determine “whether the exclusion[s] [are] necessary to promote a compelling state interest”. 8 The Court found that the restrictions imposed by the New York statute “[did] not meet the exacting standard of precision we require of statutes which selectively distribute the franchise.

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Bluebook (online)
310 F. Supp. 1172, 1970 U.S. Dist. LEXIS 12733, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stewart-v-parish-school-board-of-the-parish-of-st-charles-laed-1970.