Evans v. Cornman

Background

A group of people who live on the grounds of the National Institutes of Health (NIH), a federal reservation inside Montgomery County, Maryland, were told they did not meet the State’s residency rule and that their names would be removed from the voter rolls. Ten of the twelve had been registered and two had been denied registration because they lived on the NIH property. After a federal trial court blocked the removals and entered a permanent injunction, the case went directly to this Court.

Reasoning

The Court addressed whether people living on the NIH federal reservation are residents of Maryland for voting purposes and whether denying them the vote violates equal protection. The Justices rejected the idea that creating an enclave makes its residents outside the State for voting purposes. They emphasized many practical ties showing these residents are treated like other Marylanders: they live within the State’s geographic boundaries, are counted for apportionment, pay or are subject to many state taxes and regulations Congress allows, use state courts, register cars in Maryland, and send their children to state schools. The Court concluded that excluding them from voting could not be justified on the asserted claim that enclave residents lack sufficient interest in state affairs, and held that denying the vote violated the Fourteenth Amendment’s guarantee of equal protection.

Real world impact

The decision means the NIH residents may vote in Maryland elections and prevents election officials from removing them from the rolls for living on the enclave. It limits a State’s power to bar federal-enclave residents from the franchise unless the State shows a truly compelling and specific reason for exclusion.