In the 1976 case Town of Lockport, New York v. Citizens for Community Action at the Local Level, Inc., the Supreme Court ruled on a voting rights dispute related to local government restructuring. The town proposed changing its form of government from a town board system to one with an elected mayor and council members. This change required approval by both city and non-city residents in separate referendums under New York law. A group called Citizens for Community Action challenged this dual referendum requirement as violating their equal protection rights under the Fourteenth Amendment because it gave disproportionate influence to rural voters over urban ones. The Supreme Court upheld the dual referendum process, ruling that it did not violate equal protection principles since there was no discrimination against an identifiable class or dilution of minority voting power involved in this case. Instead, they found that differentiating between city and non-city residents reflected legitimate state interests in preserving existing forms of local governments and ensuring those affected by changes had a voice in deciding them.

In the dissenting opinion for Town of Lockport v. Citizens for Community Action at the Local Level, Justice Brennan argued that the majority's decision to uphold a New York law allowing separate voting districts in city and town areas was flawed. He believed it violated principles of equal protection under the Fourteenth Amendment because it allowed unequal representation based on geographical location rather than population size. The justice contended that this system unfairly favored rural voters over urban ones by giving them disproportionate influence in local government decisions, particularly those related to budgetary matters and public services allocation. In his view, such an arrangement contradicted previous Supreme Court rulings which emphasized "one person, one vote" as a fundamental principle of democratic governance.