Case Summary

In 1971, several Virginia voters filed a federal lawsuit challenging the state’s House of Delegates redistricting plan as unconstitutionally malapportioned in violation of the Equal Protection Clause’s one person, one vote requirement, citing the plan’s population deviations as high as 16.4% from ideal.

  • The U.S. District Court for the Eastern District of Virginia struck down the state’s plan as unconstitutional and implemented its own House of Delegates plan with a maximum population deviation of slightly more than 10%. The defendants appealed this decision and court-ordered plan to the U.S. Supreme Court, arguing the original plan’s deviations were permissible and otherwise justified by the state’s redistricting policy goal of maintaining whole political subdivisions.
  • On April 2, 1973, the U.S. Supreme Court reversed and upheld the state’s House of Delegates plan as constitutional. The Court explained that one person, one vote challenges to legislative redistricting plans are reviewed under the less stringent equal protection standard from Reynolds v. Sims, which requires states to make “honest and good faith efforts” to draw districts with “substantially” equal populations and constitutionally allows some deviations so long as they are incident to a rational state policy. Applying that here, Virginia’s plan reasonably furthered its legitimate goal of keeping political subdivisions whole and the deviations that resulted therefrom were not outside the constitutional bounds.

Significance: Legislative apportionment maps with population deviations greater than 10% are permissible under the 14th Amendment's "substantially" equal population standard so long as they result from the State's "honest and good faith" efforts to comply with equal population requirements and are reasonably motivated by legitimate redistricting policies, such as respecting political subdivisions.

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U.S. Supreme Court - 410 U.S. 315 (1973)