Facts
- Alabama’s state legislative districts had extreme population disparities, including a senate district with about 41 times as many eligible voters as another.
- Alabama’s constitution called for population-based representation and decennial reapportionment, but the legislature had effectively kept apportionment fixed since the early 1900s.
- The apportionment framework guaranteed each county at least one representative and restricted how counties could be grouped for senate districts, entrenching unequal representation.
- Jefferson County voters sued state election officials, alleging that malapportionment diluted votes in violation of the Fourteenth Amendment.
- A three-judge federal district court ruled the existing apportionment and two subsequent legislative plans unconstitutional, enjoined elections under them, and implemented a temporary court-ordered plan after concluding the state had not produced a constitutional solution.
Issues
- Whether Alabama’s legislative apportionment, producing extreme population disparities, violated the Equal Protection Clause of the Fourteenth Amendment.
- Whether equal protection requires that both houses of a bicameral state legislature be apportioned substantially on a population basis.
- Whether a federal court may impose a temporary reapportionment plan when a state fails to enact a constitutional apportionment scheme.
Decision
- The Supreme Court affirmed that Alabama’s apportionment scheme violated the Equal Protection Clause because it substantially diluted individual voting power through severe population inequalities.
- The Court held that both houses of a bicameral state legislature must be apportioned on a population basis, requiring districts of substantially equal population.
- The Court rejected reliance on county-based or geographic representation rules when they produce systematic vote dilution.
- The Court held that federal courts may fashion and implement temporary reapportionment remedies when a state fails to adopt a constitutionally valid plan and elections are imminent, while recognizing reapportionment is primarily a legislative task.
- Justice Harlan dissented, arguing the Fourteenth Amendment did not authorize this judicial control over state legislative structure and that the matter should be left to state political processes.
Legal Principles
- The Equal Protection Clause prohibits apportionment schemes that debase or dilute the weight of a citizen’s vote through grossly unequal district populations.
- In state legislative elections, equal protection requires “substantially equal” representation for all citizens; states must make honest and good-faith efforts to achieve districts as nearly equal in population as practicable.
- Bicameral state legislatures must apportion seats in both houses on a population basis; the federal Senate’s structure is not a model for intra-state representation.
- Federal courts have equitable authority to enjoin unconstitutional election schemes and, if necessary, impose interim apportionment plans to prevent elections from proceeding under unconstitutional districts.
Conclusion
The Court constitutionalized the “one person, one vote” rule for state legislatures, requiring substantial population equality in districts for both houses and authorizing federal judicial relief, including interim plans, when states fail to correct unconstitutional malapportionment.