Franklin v. Krause, 21 N.Y.2d 245 (1967)

A weighted voting plan for a local government body violates the one person, one vote principle if a legislator’s voting power, measured by the mathematical possibility of casting a decisive vote, does not approximate the power that legislator would have in a legislative body without weighted voting.

Summary

This case addresses the constitutionality of weighted voting plans implemented by Boards of Supervisors in Washington and Saratoga Counties to address malapportionment. The New York Court of Appeals held that such plans are unconstitutional if they disproportionately affect a representative’s voting power compared to their constituency’s population. The court emphasized that the mathematical possibility of casting a decisive vote, rather than actual influence, must align with population ratios. Because the counties failed to provide sufficient mathematical analysis proving the validity of their plans, the court upheld the lower courts’ decisions invalidating the plans. This ruling underscores the importance of ensuring equitable representation in local governance and avoiding disenfranchisement of smaller communities.

Facts

Washington and Saratoga Counties, recognizing malapportionment issues within their Boards of Supervisors due to population disparities among towns and cities, adopted weighted voting plans. The Washington County plan, termed the “Adjusted Weighted Voting Plan,” allocated votes based on population, with a maximum of 15 votes per supervisor, and Kingsbury, the largest town, had three supervisors each casting 13 votes. The Saratoga County plan, the “Fractional-Weighted Voting Plan,” followed a similar pattern, allocating votes per capita up to a maximum of 20 votes. Both plans were intended to give smaller towns a voice, but were challenged by residents arguing they effectively disenfranchised those smaller towns.

Procedural History

Residents of Kingsbury in Washington County and Saratoga Springs in Saratoga County separately sued their respective County Boards of Supervisors, seeking a declaratory judgment that the existing apportionment was unconstitutional and requesting the submission of a valid reapportionment plan. The trial courts found the weighted voting plans unacceptable and ordered the boards to submit alternative plans. The Appellate Division affirmed these orders, and the case was appealed to the New York Court of Appeals.

Issue(s)

1. Whether a weighted voting plan for a county board of supervisors violates the one person, one vote principle if the voting power of a representative does not roughly correspond to the proportion of the population in their constituency.
2. Whether a county board of supervisors can rely on a presumption of constitutionality for a weighted voting plan without providing mathematical analysis to demonstrate its validity.

Holding

1. Yes, because the principle of one person, one vote is violated when a representative’s power to affect legislation through their vote does not roughly correspond to their constituency’s population.
2. No, because a considered judgment on weighted voting is impossible without computer analyses; therefore, the boards must demonstrate the validity of their reapportionment plans with such analyses.

Court’s Reasoning

The Court of Appeals reasoned that while some disparity in influence among legislators is acceptable, the core principle of