Case Summary

After Missouri’s congressional plan was struck down for violating the U.S. Constitution’s one person, one vote requirements, the state’s General Assembly enacted a new congressional plan in 1967 with district population deviations as high as 3.13% and as low as 2.84% from “ideal.” Soon after, several Missouri voters filed a federal lawsuit arguing the state’s new plan still violated the one person, one vote requirement under Article I, § 2.

  • The district court struck down the plan as violating the “as nearly as practicable” equal population standard, citing the General Assembly’s rejection of a similar plan with much smaller deviations and its reliance on inaccurate data when drawing districts.
  • On April 7, 1969, the U.S. Supreme Court affirmed the district court’s decision that the map was unconstitutional. The Court rejected the state’s argument that the deviations were small enough to be considered “de minimis” and not require justification, explaining the “as nearly as practicable” equal population standard for congressional districts doesn’t permit any unjustified population deviations, no matter how small. The Court also rejected the state’s attempt to justify the deviations as resulting from their use of eligible voter population to draw districts since the state failed to clearly ascertain their exact eligible voter population figures.

Significance: The "as nearly as is practicable" equal population requirement for congressional districts under Art. I, § 2 does not permit any "de minimis" deviations from population equality, no matter how small.

Case Library

U.S. Supreme Court - 394 U.S. 526 (1969)