## Facts

- Holt, Alabama was an unincorporated community located outside Tuscaloosa’s city limits but within a three-mile area designated by Alabama law as the city’s “police jurisdiction.”
- Alabama statutes authorized certain municipalities to enforce police, sanitary, and business-licensing regulations in this extraterritorial area and to collect business license fees there, often at reduced rates compared to fees inside the city.
- Holt Civic Club and Holt residents alleged they were subject to Tuscaloosa’s ordinances and licensing exactions but could not vote in Tuscaloosa municipal elections.
- Plaintiffs filed a statewide class action in federal district court challenging the constitutionality of the police-jurisdiction statutes under the Fourteenth Amendment’s Equal Protection and Due Process Clauses.
- A three-judge district court, convened under then-applicable 28 U.S.C. § 2281, dismissed the complaint for failure to state a claim.
- Plaintiffs appealed directly to the U.S. Supreme Court.

## Issues

1. Whether the challenge to Alabama’s police-jurisdiction statutes required convening a three-judge district court under 28 U.S.C. § 2281.
2. Whether subjecting nonresidents to a city’s extraterritorial regulatory and licensing authority while denying them the right to vote in city elections violates the Equal Protection Clause.
3. Whether the same scheme violates the Due Process Clause.

## Decision

- The Court held that a three-judge district court was properly convened because the suit attacked the constitutionality of state statutes establishing a statewide system of extraterritorial municipal authority.
- The Court affirmed dismissal of the complaint.
- Equal protection: the statutes were upheld under rational-basis review because residents outside the city limits have no constitutional entitlement to vote in municipal elections and the scheme was a rational legislative arrangement.
- Due process: the statutes did not violate due process because nonresidents had no constitutional right to vote in Tuscaloosa elections.

## Legal Principles

- A governmental unit may restrict participation in its political processes to residents within its borders, even if the unit’s actions affect nearby nonresidents.
- Exclusion from a municipal franchise is not subjected to strict scrutiny when the excluded individuals reside outside the municipality’s geographic boundaries.
- Extraterritorial municipal regulation and related reduced-scale licensing fees may satisfy equal protection if rationally related to legitimate state interests, including providing police, fire, and health protection in areas adjoining city borders.
- Due process is not violated solely because nonresidents are regulated or assessed fees by a municipality without being able to vote in that municipality’s elections.

## Conclusion

The Supreme Court upheld Alabama’s statutory police-jurisdiction system, concluding that Tuscaloosa could exercise limited regulatory and licensing authority over nearby nonresidents without extending them municipal voting rights, and that the scheme satisfied equal protection and due process under rational-basis review.


Holt Civic Club v. City of Tuscaloosa, 439 U.S. 60 (1978)