Facts
- Indiana’s legislative apportionment statutes treated Marion County (Indianapolis) as a multi-member district for both houses of the state legislature and produced population deviations among districts statewide.
- Residents of Marion and Lake Counties, including Black and low-income voters from an Indianapolis “ghetto area,” challenged the statutes under the Equal Protection Clause.
- Plaintiffs alleged the multi-member structure diluted the voting strength of Black and poor voters in the ghetto area and argued that voters in multi-member districts had greater “tie-breaking” voting power than those in single-member districts.
- A three-judge federal district court found that a racial minority group with distinct legislative interests lived in the ghetto area and that the statutes minimized and canceled its voting strength.
- The district court held the statutes unconstitutional, ordered the State to enact a new plan by a set deadline, and, after legislative inaction, imposed its own statewide plan using single-member districts.
- The Supreme Court stayed the judgment, allowing the 1970 elections to proceed under the existing statutes while the appeal was pending.
- Under the challenged plan (using 1960 census data), the maximum population variance was 28.20% for senate districts and 24.78% for house districts.
- During the appeal, Indiana enacted new statewide apportionment legislation using single-member districts, but the controversy over the earlier statutes and remedies remained unresolved.
Issues
- Whether enactment of a new statewide single-member plan mooted the challenge to the prior apportionment statutes and the district court’s remedial order.
- Whether challenges to multi-member legislative districts are justiciable and, if so, what a plaintiff must prove to show unconstitutional vote dilution.
- Whether Marion County’s multi-member districting unconstitutionally diluted the voting strength of Black and low-income residents of the Indianapolis ghetto area.
- Whether the statewide population deviations violated equal protection “one person, one vote” requirements.
Decision
- The Supreme Court reversed the three-judge district court and remanded.
- The case was not moot despite subsequent enactment of a new statewide plan.
- Multi-member districts are justiciable but are not unconstitutional per se; challengers must prove discriminatory operation that dilutes or cancels a group’s voting strength.
- On the record, plaintiffs did not prove that Marion County’s multi-member scheme operated to minimize or cancel out the ghetto-area voters’ strength in a constitutionally impermissible way.
- The statewide population deviations, though near the outer range of acceptable variation, were not held unconstitutional on this record.
Legal Principles
- Multi-member districts do not violate equal protection merely by their form; invalidation requires proof that they operate to dilute or cancel the voting strength of an identifiable racial or political group.
- Equal protection does not guarantee proportional representation; repeated electoral defeat of a group’s preferred candidates, without additional proof of exclusionary operation, is insufficient.
- The burden rests on the challenger to show that the political process is not equally open to the group or that structural features fence the group out of effective participation.
- Moderate population deviations in state legislative districts may be upheld absent a showing that the deviations reflect impermissible discrimination or arbitrary state action.
- Federal courts should not displace state apportionment choices without a demonstrated constitutional violation; remedial authority must track correct constitutional standards.
Conclusion
The Court held that multi-member legislative districts are permissible absent proof of discriminatory vote-dilution effects, rejected a proportional-representation theory of equal protection, and upheld Indiana’s population deviations as not unconstitutional on the record, reversing the lower court’s statewide single-member remedy.