In the 1980 U.S. Supreme Court case Ball et al. v. James et al., the court ruled in favor of a unique voting system used by an Arizona agricultural improvement and power district, which was challenged for being unconstitutional as it allegedly violated the Equal Protection Clause of the Fourteenth Amendment. The voting system allocated votes based on acreage owned rather than one vote per person or household, thus giving more influence to large landowners within the district's boundaries. The plaintiffs argued that this method diluted their votes compared to those with larger properties, but Justice William Rehnquist wrote for a divided court that such districts are special-purpose units of government and not subject to traditional "one-person-one-vote" requirements applicable to general governmental entities like cities or counties. Rehnquist reasoned that since these districts primarily serve property interests rather than people directly, it is appropriate for property owners' voices - especially those who own more land and therefore have greater stakes - to carry more weight in decision-making processes related to water supply and electricity generation services provided by these districts.

In the dissenting opinion for Ball et al. v. James et al., Justice Brennan, joined by Justices Marshall and Stevens, argued that the voting scheme of Salt River Project Agricultural Improvement and Power District violated the Equal Protection Clause of the Fourteenth Amendment. They disagreed with the majority's view that this case was similar to Salyer Land Co. v Tulare Lake Basin Water Storage Dist., where a special-purpose district could limit voting rights based on land ownership because it disproportionately affected landowners. The dissenting justices believed that Salt River had broader powers and responsibilities than those in Salyer, including electricity supply to urban consumers who were not allowed to vote under its system; thus, they considered it more akin to a municipal corporation rather than a special purpose district limited only affecting property interests. Therefore, they concluded that one-person-one-vote principle should apply here as well.