Case Summary
In 1962, several Georgia voters filed a federal lawsuit against Georgia’s Governor and Secretary of State challenging the state’s congressional redistricting plan, which was enacted in 1931 and contained a district with two-to-three times more population than other districts in the plan, as diluting their voting strength in violation of Article I, § 2 of the U.S. Constitution, which required representatives be “apportioned among the several states . . . according to their respective numbers.”
- A three-judge district court panel dismissed the lawsuit citing the U.S. Supreme Court’s precedent that congressional apportionment-based challenges were non-justiciable political questions. Plaintiffs appealed to the U.S. Supreme Court.
- On February 17, 1964, SCOTUS reversed and struck down the congressional plan as unconstitutional. The Court held that dismissal was improper in light of its recent ruling in Baker v. Carr finding constitutional challenges to legislative apportionment laws were not non-justiciable political questions and explained that Art. I, § 2 requires that “as nearly as is practicable, one man’s vote in a congressional election is to be worth as much as another’s.”
Significance: (1) Federal courts do have jurisdiction to hear and resolve equal protection challenges to State congressional apportionment plans; (2) Article I, § 2 of the U.S. Constitution requires that State congressional districts be drawn to have strictly equal populations "as nearly as is practicable."
Case Library
U.S. Supreme Court - 376 U.S. 1 (1964)
- Opinion - 2/17/64