Toltec Watershed Improvement District was established after a referendum held under Wyoming's Watershed Improvement District Act. Under the Act, only landowners could vote, and the district could not be found administratively practicable and feasible unless a majority of votes cast, representing a majority of acreage in the district, favored creation. After the district was formed, it sought entry onto land owned by Associated Enterprises and leased by Johnston Fuel Liners to conduct studies on the feasibility of constructing a dam and reservoir. Appellants argued the district was illegally formed because the voting provisions violated the Equal Protection Clause.
Issue
Whether Wyoming's statutory scheme limiting the franchise in a watershed improvement district formation referendum to landowners and weighting votes according to acreage violates the Equal Protection Clause.
Rule
When a governmental unit is of special or limited purpose and its activities have a disproportionate effect on landowners, the State may rationally conclude that landowners are primarily burdened and benefited and may therefore limit voting to landowners and condition voting power on acreage.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
Colorado authorizes creation of a riverbank stabilization district in Pueblo. The district may only design and carry out erosion-control projects, and any benefits are financed through assessments on benefited parcels that become liens on the land until paid. State law allows only landowners within the proposed district to vote on formation, with voting power weighted by acreage.
A nonowner resident who rents an apartment in the proposed district challenges the voting scheme under the Equal Protection Clause. Which argument best supports the statute's constitutionality?
Explanation. The majority upheld landowner-only, acreage-weighted voting where the governmental unit had a special or limited purpose and its activities disproportionately affected landowners. The key features were project-based operations, land assessments for benefits received, and liens on the land, showing that landowners were primarily burdened and benefited. Under that reasoning, the Colorado scheme is constitutional.