KRAMER v. UNION SCHOOL DISTRICT

Print this Page
Case Basics
Docket No. 
258
Appellant 
Morris H. Kramer et al.
Appellee 
Union School District
Advocates
(argued the cause for the appellant)
(argued the cause for the appellees)
Tags
Term:
Facts of the Case 

Section 2012 of the New York Education Law permitted school districts to limit eligible voters in school district elections to citizens owning or leasing taxable real property and parents of children enrolled in public schools. Union School District No. 15 applied these restrictions. On April 25, 1965, Morris H. Kramer, a resident of district 15 who resided with his parents and had no children, attempted to register for the local school district elections. His application was rejected for failure to comply with the restrictions. Kramer filed a class-action suit against the school board in federal court, claiming his constitutional rights under the Equal Protection Clause of the Fourteenth Amendment had been violated. The district court initially declined to hear his constitutional claims, but, on appeal, the United States Court of Appeals for the Second Circuit directed the district court to hear Kramer's claim. On hearing the complaint, the court found no constitutional violation and denied Kramer's claim.

Question 

Did the requirement that he be a landowner or parent of a student to vote in school district elections violate Kramer's rights under the Equal Protection Clause of the Fourteenth Amendment?

Conclusion 
Decision: 5 votes for Kramer, 3 vote(s) against
Legal provision: Equal Protection

Yes. In a 5-3 decision authored by Chief Justice Earl Warren, the Court accepted Kramer's argument that all district residents share substantial interest in school meeting decisions. While the statute purported to limit voting rights to those who were "primarily interested" in the election's outcome, the Court found the structure of the law too broad to achieve this goal. The Court concluded that such restrictions must be tailored to achieve the stated goal, and the current classifications "permit inclusion of many persons who have, at best, a remote and indirect interest in school affairs and, on the other hand, exclude others who have a distinct and direct interest in the school meeting decisions."

Cite this Page
KRAMER v. UNION SCHOOL DISTRICT. The Oyez Project at IIT Chicago-Kent College of Law. 10 September 2014. <http://www.oyez.org/cases/1960-1969/1968/1968_258>.
KRAMER v. UNION SCHOOL DISTRICT, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1968/1968_258 (last visited September 10, 2014).
"KRAMER v. UNION SCHOOL DISTRICT," The Oyez Project at IIT Chicago-Kent College of Law, accessed September 10, 2014, http://www.oyez.org/cases/1960-1969/1968/1968_258.