Case Summary

In the early 1960s, a group of Alabama voters filed a federal lawsuit against various Alabama officials challenging the state’s legislative redistricting maps as violating the Alabama and U.S. Constitutions. Plaintiffs argued that Alabama’s maps, which had been drawn based off the 1900 Census and had not been updated to reflect population shifts, discriminated against voters in more populated districts by diluting the value of their votes. They asserted this failure to adjust for current populations violated the Alabama Constitution’s requirement to conduct reapportionment after each decennial census and the U.S. Constitution’s Equal Protection Clause of the 14th Amendment.

  • On June 15, 1964, the U.S. Supreme Court held Alabama’s continued use of legislative districts based off the 1900 Census violated the Equal Protection Clause. The Court stated the Equal Protection Clause requires “no less than substantially equal state legislative representation for all citizens” and, as such, states are required to make “honest and good faith efforts” to reapportion and draw their legislative districts with as nearly equal population as is practicable.

Significance: The 14th Amendment's Equal Protection Clause requires that state legislative districts be drawn with "substantially equal" populations. Some deviations are permissible so long as they are made in good faith and based on legitimate considerations incident to effectuating a rational state policy.

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U.S. Supreme Court - 377 U.S. 533 (1964)