In 1971, the Virginia General Assembly reapportioned their state's legislative districts and produced a plan wherein certain House districts' populations deviated from the overall plan's "ideal" district population by up to 16.4%. Thereafter, several registered voters in Virginia challenged the constitutionality of the House districts map in federal court, alleging that the plan's large maximum population deviation across districts violated the one person, one vote constitutional principle. The district court found for the plaintiffs, struck down the House plan, and substituted its own House apportionment plan with a maximum population variation of slightly over 10%. The defendants-state officials appealed the district court's ruling and substituted plan, arguing that the original plan's deviations were permissible and otherwise justified by the state's policy of maintaining the integrity of political subdivisions when reapportioning the legislature.
In 1973, the U.S. Supreme Court reversed the district court's decision and held that the General Assembly's original plan did not violate the one person, one vote principle. The Court conclusively stated that challenges to legislative apportionments are to be judged under the less stringent Equal Protection standard from Reynolds v. Sims, which requires states make an "honest and good faith effort" to draw districts with "substantially" equal populations and constitutionally permits some deviations so long as they are incident to the effectuation of a rational state policy. Applying this test, the Court found that Virginia's plan reasonably advanced the state's legitimate goal of maintaining existing political subdivisions, and the deviations that resulted therefrom did not fall outside the constitutional limits due to this justification.
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.
U.S. Supreme Court - 410 U.S. 315 (1973)
- Opinion - 4/2/73