Despite a 1901 state law providing for the decennial reapportionment of the state's legislative districts based upon the Federal Census, from 1901 to 1961 Tennessee did not reapportion their state's legislative districts and continued to use the legislative apportionment plan adopted in, and based upon population figures from, 1901. In 1961, several Tennessee citizens filed a federal lawsuit against various elected Tennessee officials alleging that the state's failure to reapportion their state's legislative districts in order to reflect the substantial population growths and shifts that had taken place over the past sixty years devalued their votes in violation of the Equal Protection Clause of the 14th Amendment. Before reaching the U.S. Supreme Court on appeal, the federal district court had dismissed the plaintiffs claims citing the longstanding federal precedent that federal courts lacked subject matter jurisdiction over disputes involving legislative apportionment plans because they were non-justiciable political questions.
In 1962, the U.S. Supreme Court issued a landmark opinion in favor of the plaintiff-appellants, ruling for the first time that federal courts did in fact have subject matter jurisdiction over Equal Protection challenges to legislative apportionment plans. The Court explained that equal protection claims alone do not require the court to render decisions as to any political questions but rather as to individuals' constitutional rights, and the mere fact that such claims might arise out of a matter affecting state government does not automatically render the case nonjusticiable. The Court stated that federal courts have always had subject matter jurisdiction over alleged denials of equal protection, and such cases present a justiciable, constitutional cause of action for which the federal courts can fashion a remedy.
Significance: Federal courts do have jurisdiction to hear and resolve equal protection challenges to state legislative apportionment plans.
U.S. Supreme Court - 369 U.S. 186 (1962)
- Opinion - 3/26/62