Chappelle v. Greater Baton Rouge Airport District

Background

E. C. Chappelle, Jr. sought appointment as a commissioner on the Greater Baton Rouge Airport Commission but was deemed unqualified because Louisiana Act 151 of 1969 required commissioners to own property assessed in East Baton Rouge Parish. The dispute moved through the Louisiana courts and reached the Supreme Court on appeal from the Court of Appeal of Louisiana for the First Circuit.

Reasoning

The central question was whether a law that bars appointment unless a person owns property assessed in a particular parish can constitutionally prevent that person from serving. The Supreme Court reversed the lower-court judgment and cited Turner v. Fouche. The practical effect of the reversal was to reject the property-ownership barrier that had been used to deny Chappelle’s appointment, allowing a person without parish-assessed property to be eligible for the commission seat.

Real world impact

The decision affects local appointment rules that tie eligibility to owning assessed property. People who lack property assessed in the parish may no longer be excluded from serving on this airport commission by that specific rule. Local governments that use similar property-ownership qualifications will likely need to reconsider whether those rules can continue to block appointed candidates.

Dissents or concurrances

Justice Rehnquist dissented, arguing that the Constitution and prior decisions have allowed residency and similar qualifications, and that a legislature could reasonably require property ownership to ensure officials have a direct interest in the local office.