Case Summary

In 1971, several Texas voters filed a federal lawsuit against Texas’s Secretary of State challenging the state’s congressional redistricting plan as violating the one person, one vote requirement under Article I, § 2 of the U.S. Constitution, citing the plan’s population deviations ranging from -1.7% and +2.43% from ideal. The State defended its plan on the grounds the variances were constitutionally necessary in order to achieve the state’s policy goal of preserving incumbents’ district boundaries and maintaining constituent relationships.

  • On June 18, 1973, the U.S. Supreme Court struck down the plan as violating Article I, § 2’s equal population requirements. It explained that although the State’s asserted policy was legitimate and could justify minor population deviations, it couldn’t do so here since at least one alternative plan was proposed which achieved that goal while also producing more equally populated districts.

Significance: Article I, § 2 strictly requires that congressional district populations be "as mathematically equal as reasonably possible," and population variances among those districts are only constitutionally permissible if they are shown to be "unavoidable" despite a good faith effort to achieve absolute equality or are otherwise justified by the State.

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U.S. Supreme Court - 412 U.S. 783 (1973)