Kramer v. Union Free School District No. 15

Morris H. Kramer was a 31-year-old unmarried man who lived with his parents in Atlantic Beach, New York, within Union Free School District No.

He contended that the statute violated his rights under the Equal Protection Clause of the Fourteenth Amendment, as it had been construed in recent Supreme Court decisions such as Harper v. Virginia State Board of Elections.

[3] He concluded that the "distinctions drawn by the legislature of the State in Section 2012 of the New York Education Law are so clearly reasonable and plaintiff's claim so obviously without merit, that it can only be characterized as frivolous."

Writing for the Second Circuit panel majority, Judge Paul R. Hays concluded that in light of then-recent Supreme Court caselaw applying the Equal Protection Clause to voter restrictions, Kramer's constitutional challenge could not be considered frivolous.

District Judge Jack Weinstein dissented, opinion that Section 2012 "impose[d] a forbidden property qualification for voting" in violation of the equal protection guarantee.

Chief Justice Warren's opinion began by observing that under then-recent Equal Protection Clause caselaw, alleged infringements of the right to vote must survive careful judicial scrutiny, because "any unjustified discrimination in determining who may participate in political affairs or in the selection of public officials undermines the legitimacy of representative government."

According to Justice Stewart's dissenting opinion, a statute violates the Equal Protection Clause only if it rests on grounds wholly irrelevant to achieving the legislature's objectives.

Under Lassiter v. Northampton County Board of Elections, Justice Stewart argued, states may impose restrictions on voting so long as they are reasonably designed to promote intelligent use of the franchise.

In reaching this conclusion, the Court observed that the water district exercised "a special limited governmental function" that had "a disproportionate effect on landowners."

In Ball v. James,[11] a closely divided Court reached the same conclusion with respect to elections in Arizona water reclamation districts.

Morris Kramer, now in his 70s, still lives in the same house in Atlantic Beach, New York as he did when he sued the school district more than 40 years ago, according to a recent interview in a community newspaper discussing his career as a "civic and environmental activist" on Long Island.