Hill v. Stone
Headline: Court strikes down Texas rule limiting bond-election voting to those who 'render' property, expanding ballot access for residents otherwise excluded and barring similar future voting restrictions in bond elections.
Holding:
- Bars excluding residents from bond elections for failing to 'render' property for taxation.
- Invalidates Texas dual-box practice and similar future restrictions on bond-election voting.
- Leaves already finalized bond authorizations intact; applies only to elections not final at judgment.
Summary
Background
Residents of Fort Worth sued to challenge Texas and city laws that limited voting in municipal bond elections to people who had "rendered" property for taxation. In 1972 Fort Worth used a dual-box system: those who had rendered property voted in one box and all other registered voters in another. Of about 29,000 participants, roughly 24,000 voted as renderers and 5,000 as nonrenderers. A library bond passed by an overall majority but failed in the renderers' box and so was declared not authorized. A three-judge federal court found the rendering requirement unconstitutional and ordered nonrenderers’ ballots counted; Texas appealed.
Reasoning
The Court addressed whether a rendering requirement is permissible in a general-interest bond election. Relying on prior decisions, it held that general obligation bond elections are of general interest and that classifications restricting suffrage beyond residence, age, and citizenship must meet a compelling-state-interest test. The Court concluded the Texas rule effectively disfranchised voters who had not rendered property and that the State's justifications—protecting property owners or encouraging tax compliance—did not meet the required justification because rendering could be trivial and did not measure real burden.
Real world impact
The decision invalidates Texas provisions that limit bond-election voting to those who have rendered property and prohibits similar future restrictions in bond elections. The Court affirmed the lower court's judgment but limited its effect: it will not disturb bond authorizations that were final before the district court judgment. The ruling ends the dual-box practice in future bond elections where state law resembles Texas.
Dissents or concurrances
Justice Rehnquist, joined by the Chief Justice and Justice Stewart, dissented. He argued the rendering rule imposed at most a de minimis burden because anyone could qualify by listing even trivial property, and he would have remanded for factual findings about how the rule operated in practice.
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