Since the start of the 1900s, Georgia had utilized a "county unit" electoral system for primary elections for statewide offices wherein the candidate receiving the highest number of votes in a county would receive all of that county's vote units, and the candidate who received a majority of county vote units statewide would win overall. In 1962, several Georgia voters filed a federal lawsuit against the Georgia Secretary of State and State Democratic Executive Committee seeking to have the county unit system declared unconstitutional. Under this system, a majority of the state's county unit votes were determined by rural counties containing only one-third of the state's population, and the plaintiffs argued that such a disproportionately weighted voting system violated the Equal Protection and Due Process Clauses of the 14th Amendment.
In 1963, the U.S. Supreme Court issued an 8-1 opinion in favor of the plaintiffs, striking down Georgia's use of the "county unit" system as unconstitutional under the 14th Amendment's Equal Protection Clause. The Court's ruling hinged upon the majority's recognition, for the first time, of the "one person, one vote" principle as a constitutional standard in voting rights and apportionment cases. The majority opinion explained that the concept of "political equality" underpinning the Declaration of Independence, the 15th, 17th, and 19th Amendments, and prior court rulings, can only be understood as requiring the one person, one vote standard because such a principle is necessary to ensure the equality of voting power is not unconstitutionally evaded.
Significance: Recognized, for the first time, the constitutional principle of "one person, one vote" as a guiding standard for election law and apportionment cases.
U.S. Supreme Court - 372 U.S. 368 (1963)
- Opinion - 3/18/63