The Midland County Commissioners Court, which had authority over the taxation, expenditures, and general governance of Midland County, Texas, was comprised of five members, with one being elected at large and the remaining four being elected from each of four single-member districts. One of these districts contained the city of Midland and had a population of over 67,000, while the remaining three districts all had populations of less than 1,000. In 1967, a taxpayer in Midland County filed suit in Texas state court challenging the county commissioner apportionment, alleging that the substantially unequal populations for the local election districts violated the 14th Amendment's Equal Protection Clause.
In 1968, the U.S. Supreme Court ruled in favor of the plaintiff, finding that the Commissioner Court districts' unequal populations violated the Equal Protection Clause. The Court explained that when local governmental units, like the Commissioners Court here, exercise general governmental powers over the area that elected them, the One Person, One Vote constitutional principle applies and prohibits "substantial variations" from equal population in their electoral districts. In doing so, the Court recognized for the first time that the U.S. Constitution's requirements and restrictions relating to apportionment apply equally to local elections and electoral districts.
Significance: The One Person, One Vote constitutional principle applies to local government electoral districts and apportionments.
U.S. Supreme Court - 390 U.S. 474 (1968)
- Opinion - 4/1/68