## Facts

- California created the Tulare Lake Basin Water Storage District under a state water storage district statute to acquire, store, and distribute irrigation water for agricultural lands.
- The District was a special-purpose governmental entity that did not provide general public services.
- District expenses were financed solely through assessments levied on landowners within the District.
- State law limited the right to vote for the District’s board of directors to landowners within the District, whether or not they resided there.
- Votes were weighted in proportion to the assessed valuation of the voter’s land.
- Lessees (including tenant farmers) were not entitled to vote as lessees.
- Landowners and lessees filed a federal equal protection challenge to the landowner-only and weighted voting system.
- A three-judge federal district court upheld the voting system, and the challengers appealed to the U.S. Supreme Court.

## Issues

1. Whether the Equal Protection Clause requires “one person, one vote” for elections in a special-purpose water storage district.
2. Whether restricting the franchise to landowners in the district violates equal protection.
3. Whether weighting votes by assessed land value violates equal protection.
4. Whether excluding lessees from the franchise violates equal protection.

## Decision

- The Supreme Court affirmed, upholding the district’s landowner-only, assessed-value weighted voting scheme.
- The Court held that strict “one person, one vote” rules applicable to general-purpose governments did not control given the district’s special, limited purpose and the disproportionate impact of its activities on landowners.
- Limiting the vote to landowners was constitutionally permissible because landowners alone bore the district’s financial burdens through assessments and received the primary land-related benefits.
- Excluding lessees was permissible because their interests could be less direct than owners’ interests and voting rights could be allocated by contract (including use of proxy arrangements).
- Weighting votes by assessed valuation was permissible where both the costs and the benefits of the district’s operations were proportional to assessed land value.

## Legal Principles

- The Equal Protection Clause does not require strict population-based electoral equality for a special-purpose governmental entity whose functions are narrow and whose operations primarily affect a definable group more than the public at large.
- A landowner-only franchise may satisfy equal protection when the entity’s activities and financing fall disproportionately on landowners and the entity provides no general public services.
- Property-based vote weighting may be upheld when it reasonably reflects proportional burdens and benefits tied to land, rather than serving as a general wealth qualification.
- Exclusion of non-owner stakeholders (such as lessees) may be upheld when their interests are comparatively indirect and state law permits practical contractual allocation of voting influence.

## Conclusion

The Court sustained a statutory scheme restricting and weighting voting in a water storage district because the district’s limited functions and assessment-based financing made it reasonable to align electoral control with landownership and land value, placing the case outside standard “one person, one vote” requirements for general-purpose governments.


Salyer Land Co. v. Tulare Lake Basin Water Storage Dist., 410 U.S. 719 (1973)