Sayler Land Co. v. Tulare Lake Basin Water Storage District: Opening the Floodgates in Local Special Government Elections

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 analyze the merits and deficiencies of the techniques that the Court used in dealing with problems of local elections prior to Salyer and, against that background, will discuss the techniques used in Salyer to reconcile the competing policies. It is the thesis of this Note that the Salyer method is suitable for resolving the tension between the need for local structural flexibility and the constitutional right to equal representation and that the result reached in that case was proper. However, as the discussion of Salyer will reveal, the method has a potential for misapplication. The determination of when the need for local flexibility should override the constitutional right requires a more careful examination of the relevant factors than the Salyer opinion indicates that the Court will perform. Although the result in Salyer seems sound, a superficial analysis in future cases could give inadequate protection to the constitutional right.