Kessler v. Grand Central District Management Association, Inc.
United States Court of Appeals for the Second Circuit
158 F.3d 92 (1998)
New York authorized business-improvement districts (BIDs) funded by property-owner assessments to supplement, not replace, municipal services, with management associations whose boards had to be majority property owners rather than tenants. Kessler and Cheikes (plaintiffs), residents of the Grand Central BID, sued GCDMA (defendant), arguing its board elections needed to comply with one-person one-vote because the BID exercised sufficient governmental power; the district court granted GCDMA summary judgment, finding the BID a limited-purpose entity disproportionately affecting one class of constituents.
Whether business-improvement districts providing services supplemental to a municipality's services, and disproportionately affecting a single class of constituents, are subject to the one-person one-vote requirement.