Facts
- Georgia’s 1931 congressional apportionment statute created ten congressional districts that were not adjusted after major population shifts.
- By the 1960 census, Georgia’s Fifth District had about 823,680 residents, while the statewide average district population was about 394,312, and the Ninth District had about 272,154.
- Qualified voters in the Fifth District sued the Governor and Secretary of State in federal court, seeking declaratory and injunctive relief barring elections under the existing districting law.
- A three-judge district court acknowledged the Fifth District’s population was “grossly out of balance” but dismissed the case for “want of equity,” treating it as a nonjusticiable political question.
- The Supreme Court noted probable jurisdiction to review the dismissal.
Issues
- Whether a federal court may adjudicate a claim that a state’s congressional districting scheme unconstitutionally dilutes votes, or whether the claim presents a nonjusticiable political question.
- Whether Article I, § 2 requires states to draw congressional districts so that, as nearly as practicable, votes are equally weighted through substantially equal district populations.
- Whether Georgia’s large interdistrict population disparities violated Article I, § 2 by debasing and diluting the voting power of residents of overpopulated districts.
Decision
- The Supreme Court reversed and remanded.
- The Court held the vote-dilution challenge to congressional districting was justiciable and not subject to dismissal as a political question.
- On the merits, the Court held that Article I, § 2 requires that, as nearly as practicable, one person’s vote in a congressional election be worth as much as another’s.
- The Court concluded Georgia’s population disparities among congressional districts “grossly discriminated” against voters in the Fifth District and violated Article I, § 2.
- The Court left the precise form of declaratory and injunctive relief for the district court to determine on remand.
Legal Principles
- Claims alleging debasement or dilution of the right to vote caused by a state’s congressional apportionment are justiciable in federal court.
- Article I, § 2’s command that Representatives be chosen “by the People” requires states to achieve population equality among congressional districts “as nearly as is practicable.”
- Large population disparities among congressional districts within a state unconstitutionally dilute the weight of votes in overpopulated districts.
Conclusion
The Court held that federal courts can review congressional districting for vote dilution and that Article I, § 2 demands congressional districts be drawn with substantially equal populations so each vote carries roughly equal weight, invalidating Georgia’s severely malapportioned districts and remanding for appropriate relief.