Wednesday, November 6, 2013

Kramer v. Union Free School District case brief

Kramer v. Union Free School District case brief summary
395 U.S. 621 (1969)

Appellant citizen sought review of an order from the United States District Court for the Eastern District of New York, which dismissed appellant's complaint against appellee school district. The complaint alleged that N.Y. Educ. Law § 2101 denied appellant equal protection in violation of U.S. Constitutional Amendment XIV.

Appellant citizen, a bachelor who neither owned nor leased taxable real property, filed suit in federal court claiming that N.Y. Educ. Law § 2012 denied him equal protection of the laws in violation of U.S. Constitutional XIV. The statute limited individuals who were eligible to vote in school district elections to property owners and parents. The district court dismissed the suit, and appellant challenged the decision.


  • On appeal, the Court reversed the district court's judgment and remanded the case, finding that N.Y. Educ. Law § 2012 did violate the Constitution. 
  • The Court held that § 2012 did not meet the exacting standard of precision required of statutes that selectively distributed the franchise. 
  • The classifications in § 2012 permitted inclusion of many persons who had, at best, a remote and indirect interest in school affairs and, on the other hand, excluded others who had a distinct and direct interest in the school meeting decisions.

The Court reversed and remanded the district court's order dismissing appellant citizen's suit challenging the denial of his right to vote in the elections of appellee school district. The Court held that a statute limiting the right to vote in the elections did not meet an exacting standard of precision.

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