Kramer v. Union Free School District No. 15
| Kramer v. Union Free School District No. 15 | |
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| Argued January 16, 1969 Decided June 16, 1969 |
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| Full case name | Kramer v. Union Free School District No. 15, Town of Hempstead |
| Citations | 395 U.S. 621 (more)
89 S. Ct. 1886; 23 L. Ed. 2d 583; 1969 U.S. LEXIS 1261
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| Holding | |
| Where a state statute grants the right to vote to some bona fide residents of requisite age and citizenship and denies the franchise to others, it must be determined whether the exclusions are necessary to promote a compelling state interest. | |
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| Case opinions | |
| Majority | Warren, joined by Douglas, Brennan, White, Marshall |
| Dissent | Stewart, joined by Black, Harlan |
Kramer v. Union Free School District No. 15, 395 U.S. 621 (1969), was a United States Supreme Court decision in which the Court struck down a longstanding New York State statute requiring that to be eligible to vote in certain school district elections, an individual must either own or rent taxable real property within the school district, be the spouse of a property owner or lessor, or be the parent or guardian of a child attending a public school in the district. By a 5-to-3 vote, the court held that these voting requirements violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.
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. 15, Town of Hempstead (now the Lawrence Union Free School District). Kramer, who was registered to vote in national and state elections, sought to register to vote in the school district's annual school board election and school budget vote.
Kramer undisputedly met the age, citizenship, and residency requirements to vote in the election. However, he was not eligible to vote in school elections under Section 2012 of the New York State Education Law, which provided that to vote in school elections, a resident must either own or lease taxable real property within the school district, be the spouse of a property owner or lessor, or be the parent or guardian of one or more children enrolled in a public school within the district.
Kramer filed his complaint, seeking to enjoin the school district from enforcing Section 2012 against him, in the United States District Court for the Eastern District of New York. 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. The school district argued that the statute validly limited the franchise in school elections to those primarily affected by the results of the election, namely property taxpayers in the school district and parents of children attending the district's schools.
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