In 1971, Texas reapportioned their state's congressional districts and adopted a plan wherein several districts' populations varied significantly from that of the ideal district's population, ranging from 2.43% higher in the 13th District to 1.7% lower in the 15th District. Soon thereafter, Texas voters across several districts filed a federal lawsuit against the Texas Secretary of State, alleging that the sizable population variances in the state's congressional districts were not necessary and, therefore, violated the stringent requirement for equally populated congressional districts under Art. I, Sec. 2 of the U.S. Constitution. The defendant-Secretary of State argued that the plan's variances were constitutionally permissible because they were absolutely necessary (i.e. unavoidable) in order to further the state's policy goal of preserving incumbent representatives' districts and maintaining their existing relationships with their constituents.
In 1973, the U.S. Supreme Court ruled in favor of the plaintiff-appellees, holding that the state's congressional district plan failed to comply with the equal population requirements of Art. I, Sec. 2. The Court recognized that although the State's asserted policy goal of preserving incumbents' districts was a permissible consideration that could potentially justify minor population deviations across congressional districts, it could not justify the deviations in this case because there existed at least one alternative plan that sufficiently furthered that goal while also producing more equally populated districts. Art. I, Sec. 2 requires congressional district populations be "as mathematically equal as reasonably possible," and so, any congressional plan which contains "avoidable" population deviations violates that standard, regardless of the State's proffered justification.
Significance: Article I, Section 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.
U.S. Supreme Court - 412 U.S. 783 (1973)
- Opinion - 6/18/73