## Facts

- Arizona created the Salt River Project Agricultural Improvement and Power District as a political subdivision in central Arizona.
- The District stored and delivered untreated water to owners of roughly 236,000 acres of land.
- To finance water operations, the District sold electricity to hundreds of thousands of residents in an area including much of metropolitan Phoenix.
- Arizona law limited voting for the District’s board of directors to landowners within the District and weighted votes by acreage (“one-acre, one-vote”).
- A class of registered voters residing within the District who owned no land or less than one acre challenged the franchise as violating equal protection because the District’s policies affected them, including through electricity service.
- The federal district court upheld the voting scheme; the Ninth Circuit reversed, applying the one-person-one-vote rule; the Supreme Court reversed the Ninth Circuit.

## Issues

1. Whether the Fourteenth Amendment’s Equal Protection Clause requires one-person-one-vote for elections of the District’s directors.
2. Whether a landowner-only, acreage-weighted franchise is permissible when a governmental unit’s functions are claimed to be “special-purpose” and disproportionately affect landowners.

## Decision

- The Supreme Court reversed the Ninth Circuit and upheld the District’s landowner-only, acreage-weighted voting system.
- The Court held, 5–4, that the District was a special-purpose governmental unit exempt from strict one-person-one-vote requirements.
- The Court concluded the voting scheme had a reasonable relationship to the District’s statutory objectives because the District’s primary purpose and burdens fell disproportionately on landowners.

## Legal Principles

- One-person-one-vote applies strictly to general-purpose governmental bodies, but not necessarily to special-purpose entities with limited functions and disproportionate effects on a defined class.
- For a special-purpose district whose activities bear disproportionately on landowners, a landowner-based, acreage-weighted franchise may satisfy equal protection if reasonably related to statutory objectives.
- In assessing whether strict equal voting weight is required, courts consider whether the entity exercises typical governmental powers (e.g., broad lawmaking, general taxation, or provision of ordinary municipal services) versus performing specialized functions.
- A district’s substantial operations affecting non-landowners (such as selling electricity) do not alone require one-person-one-vote if those operations are treated as incidental to, or financing mechanisms for, the district’s specialized statutory mission.

## Conclusion

The Court held that equal protection did not require one-person-one-vote for this water-focused special-purpose district and sustained a landowner-only, acreage-weighted voting scheme as reasonably related to the District’s statutory functions and the landowners’ disproportionate burdens.


Ball v. James, 451 U.S. 355 (1981)