County voters and non-profit organization brought action against county’s Board of Commissioners, School Board, and Supervisor of Elections in his official capacity, alleging county’s districting scheme, which included all prison inmates in population base in one of its five districts, violated “one person, one vote” principle of Fourteenth Amendment’s Equal Protection Clause. Parties moved for summary judgment.
The District Court held that:
- Inmates lacked meaningful representational nexus with Boards, as required for scheme to violate “one person, one vote” principle of Equal Protection Clause, and
- Inclusion of inmate population as part of voting population in scheme diluted representational and voting strength of voters of other districts, thereby violating voters’ Equal Protection rights under principle of “one person, one vote.”
County’s prison inmates lacked meaningful representational nexus with Board of Commissioners and School Board, as required for county’s voting scheme, which included all of inmates in population base in one of its five districts, to violate “one person, one vote” principle of Equal Protection Clause. Conditions of confinement at prison were almost entirely determined by policies set at state level and by prison officials acting under state law, most of inmates had very little meaningful opportunity to engage with members of the non-incarcerated public, those who were allowed to engage with public had to do so under conditions prescribed by prison officials, and district representatives on the Boards had not made any meaningful effort to engage with prisoners.
Inclusion of inmate population at county prison, which was fully located within one of county’s five districts, as part of voting population in districting scheme diluted representational and voting strength of voters of other districts, thereby violating voters’ Equal Protection rights under principle of “one person, one vote.” True voting population of district containing prison was about two-thirds the population of other districts, which gave that district’s voters about one-and-a-half times the voting strength of voters in other districts.