CASE SUMMARY

In the early 1970s, several groups of plaintiffs filed various federal lawsuits challenging the Texas Redistricting Board’s adopted legislative redistricting plans as violating the U.S. Constitution’s 14th Amendment. Plaintiffs argued the plans were malapportioned in violation of the one person, one vote requirement and that the state House plan used 11 multi-member districts to unconstitutionally discriminate and dilute the voting strength of minority voters in Bexar and Dallas Counties.

  • A three-judge panel of the U.S. District Court for the Western District of Texas upheld the state Senate plan but struck down the state House plan as unconstitutionally malapportioned and as racially discriminatory. Defendants appealed to the U.S. Supreme Court.
  • On June 18, 1973, SCOTUS reversed the district court’s one person, one vote decision but affirmed its finding that the multi-member districts were racially discriminatory. The Court explained that it was an error for the lower court to find the plan’s 9.9% population deviation, standing alone, was sufficient to establish a 14th Amendment one person, one vote violation, noting that legislative districts aren’t subject to the stricter population equality standards under Article I, § 2 like congressional districts. It also explained that while multi-member districts are not per se unconstitutional, there was sufficient evidence here that their use, in conjunction with the official and historical racial discrimination in the two counties, caused minority voters to have less opportunity to participate in the political process and elect candidates of their choice.

CASE LIBRARY

U.S. Supreme Court - No. 72-147 [412 U.S. 755 (1973)]