In the early 1960s, a group of voters in several Alabama counties filed suit against various Alabama officials, alleging that the state's legislative apportionment maps were unconstitutional under both the Alabama and Federal Constitutions. The plaintiffs alleged that the state's legislative districts, which had been drawn based on the 1900 census and had not been updated to reflect population shifts reported by subsequent decennial censuses, discriminated against voters in districts whose populations had grown far more than others since 1900. The plaintiffs argued that in failing to update the districts to reflect current populations, the districts violated the Alabama Constitution's explicit mandate to conduct reapportionment after each decennial census as well as the Equal Protection Clause of the 14th Amendment.
In 1964, the U.S. Supreme Court ruled 8 to 1 in favor of the plaintiffs, finding that Alabama's continued use of legislative districts based off the 1900 census violated the Equal Protection Clause. The Court stated that 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.
U.S. Supreme Court - 377 U.S. 533 (1964)
- Opinion - 6/15/64