Case Summary

Despite a state law requiring its legislative districts to be redrawn every 10 years based off the results of the Federal Decennial Census, Tennessee had used the same legislative districts from 1901 to 1961. In 1961, several Tennessee citizens filed a federal lawsuit against various Tennessee elected officials alleging the state’s failure to reapportion its legislative districts to reflect population growths and shifts diluted the strength of their votes in violation of the 14th Amendment’s Equal Protection Clause.

  • The federal district court dismissed the plaintiffs’ claims, citing longstanding precedent that federal courts lacked jurisdiction over disputes involving legislative apportionment plans because they were nonjusticiable political questions. Plaintiffs appealed to the U.S. Supreme Court.
  • On March 26, 1962, SCOTUS reversed, holding for the first time that federal courts did have subject matter jurisdiction to hear, decide, and fashion remedies for Equal Protection claims against legislative apportionment plans. The Court explained such claims don’t actually require the court to decide any political questions but rather individuals’ constitutional rights, and the mere fact those claims might ultimately impact state government does not automatically render them nonjusticiable.

Significance: Federal courts do have jurisdiction to hear and resolve equal protection challenges to state legislative apportionment plans.

Case Library

U.S. Supreme Court - 369 U.S. 186 (1962)