Holt Civic Club v. City of Tuscaloosa

Summary

The Court held that Alabama's statutory system authorizing cities to exercise limited police, sanitary, licensing, and criminal jurisdiction beyond their corporate limits does not violate the Equal Protection or Due Process Clauses merely because residents of the surrounding police jurisdiction cannot vote in the city's municipal elections. Because the residents live outside the city's geographic boundaries, the voting qualification was not subject to heightened scrutiny, and the statutory scheme was rationally related to legitimate state purposes. Justice Stevens concurred to emphasize the limited scope of the holding, while Justice Brennan, joined by Justices White and Marshall, would have invalidated the statutes under heightened equal-protection scrutiny.