League of United Latin American Citizens v. City of San Marcos, No. 18-50655 (5th Cir. 2019)Annotate this Case
LULAC filed suit against the Edwards Aquifer Authority, alleging that the Authority's electoral scheme violated the "one person, one vote" principle of the Equal Protection Clause of the Fourteenth Amendment. The Fifth Circuit granted summary judgment for the Authority, holding that the Authority's powers are expressly tailored to protecting the quantity and quality of groundwater in the Edwards Aquifer and do not extend to any surface water or other aquifers located within its jurisdiction; the Authority's limited functions disproportionately impact the western agricultural and eastern spring-flow counties, whose residents are most empowered by its elections; and the Authority's electoral scheme was rationally related to the legitimate goal of protecting the aquifer because it equitably balances the rival interests of the agricultural, spring-flow, and urban counties to ensure that no one region can dominate the aquifer's management. Furthermore, the apportionment scheme was likely necessary to ensure the creation of the Authority.