Constitutional Law–Equal Protection–Property Ownership Qualifications on the Right To Vote in Special Municipal Elections–Cipriano v. City of Houma

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, established that any voter qualification based on property ownership violates the equal protection clause. The three-judge federal district court rejected this argument, one judge dissenting; held, the denial to residents who do not own property of the right to vote in municipal elections on the issuance of revenue bonds for public utilities does not violate the equal protection clause of the fourteenth amendment.