## Facts

- Connecticut enacted Public Act 821 (1971), authorizing creation or reorganization of regional councils of governments in planning regions, including the 29-town Capitol Region.
- A new regional council would be formed if at least 60% of towns in the region approved participation.
- Each member town would have one representative on the council: the town’s chief elected official.
- Hartford comprised roughly 24% of the region’s population but, under the contemplated structure, would not receive representation proportionate to its population.
- Education/Instruccion, Inc. and three individual residents sued state/regional officials and federal HUD officials, seeking declaratory and injunctive relief against implementation of the statute and related actions.
- Plaintiffs alleged the one-town/one-representative design underrepresented Hartford residents and violated the Fourteenth Amendment under the one-person, one-vote doctrine.
- The district court dismissed for failure to state a claim; plaintiffs appealed.

## Issues

1. Whether a regional council of governments with one representative per member municipality, regardless of population, violates the Equal Protection Clause under the one-person, one-vote rule.
2. Whether the challenged regional council is the type of governmental body that must be apportioned on a population basis.

## Decision

- The Second Circuit affirmed dismissal of the complaint.
- The court held that the regional council was not a general-purpose legislative body exercising broad governmental power over individuals.
- Because the council’s role was limited and primarily intergovernmental (planning and coordination among municipalities), strict population-based apportionment was not constitutionally required.
- A one-town/one-representative structure, without more, did not state an Equal Protection violation.

## Legal Principles

- The one-person, one-vote requirement applies most strongly to representative bodies that exercise general governmental powers over individuals.
- Special-purpose or limited-function governmental entities that primarily affect member governments as governmental units may be structured without strict population-based representation.
- Equal Protection does not mandate population-proportional voting for intermunicipal councils oriented toward planning and coordination rather than general lawmaking.

## Conclusion

The court upheld Connecticut’s statutory scheme for a regional council of governments, concluding that the Equal Protection Clause did not require population-proportional representation because the council functioned as a limited, municipal-focused planning and coordinating body rather than a general-purpose governmental legislature.


Educ. Instruccion, Inc. v. Moore, 503 F.2d 1187 (2d Cir. 1974)