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Sayler Land Co. V. Tulare Lake Basin Water Storage District: Opening The Floodgates In Local Special Government Elections, Michigan Law Review

Michigan Law Review

In judicial review of the constitutionality of representational structures at the local governmental level, each citizen's constitutional right to equal representation must be reconciled with the need for flexibility in designing local structures. Last term, in Salyer Land Co. v. Tulare Lake Basin Water Storage District, the Supreme Court faced this problem in the context of a water storage district. It upheld a statute that both restricted the franchise in the election of district directors to district landowners and allocated votes on the basis of the assessed value of the land owned by each voter. This Note will first …