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Constitutional Law--Equal Protection--Property Ownership Qualifications On The Right To Vote In Special Municipal Elections--Cipriano V. City Of Houma, Michigan Law Review
Constitutional Law--Equal Protection--Property Ownership Qualifications On The Right To Vote In Special Municipal Elections--Cipriano V. City Of Houma, Michigan Law Review
Michigan Law Review
Plaintiff, a resident of Houma, Louisiana, who owned no real property, brought a class action seeking to prevent the city from issuing utility revenue bonds approved by a vote of the property taxpayers at a special election. He argued that the Louisiana statute restricting the right to vote in such elections to property owners was unconstitutional. Plaintiff relied on Harper v. Virginia Board of Elections, in which the Supreme Court declared that Virginia's required payment of poll taxes for voting in general elections was a violation of the equal protection clause of the fourteenth amendment. Harper, he claimed, …
Reapportionment--Legislative Bodies--Significant Deviation From Standard Of Substantial Population Equality Of State Legislative Districts Is Permissible To Provide Representatives For Two Island Counties--Vigneault V. Secretary Of The Commonwealth, Michigan Law Review
Michigan Law Review
Since Baker v. Carr, when the Supreme Court overruled a long line of earlier decisions and concluded that the relationship of the equal protection clause to a state's power to create geographical districts for legislative representation was a justiciable issue, state apportionment plans have come under increasing judicial scrutiny. In Gray v. Sanders, the Court held invalid a Georgia primary election plan which favored voters from rural areas. Although Gray dealt with the dilution of individual voting rights rather than legislative reapportionment, it is important as the first enunciation of the now-famous "one man-one vote" test. Specifically, the …