Baker v. Carr

Facts

Tennessee's Constitution required an enumeration of qualified voters every ten years and an apportionment of seats in the General Assembly among the counties according to the number of qualified voters in each. The Assembly had a Senate of 33 members and a House of 99 members. It reapportioned itself each decade from 1871 to 1901, when it passed the Apportionment Act at issue. In the more than 60 years since, every proposal in either House to reapportion failed. Meanwhile the State's population grew and shifted, and the counties' relative standing in qualified voters changed significantly. Voters living in Davidson, Hamilton, Knox, Montgomery and Shelby Counties sued the State's Secretary of State, Attorney General, Coordinator of Elections and members of the State Board of Elections. They alleged that the 1901 statute apportioned seats arbitrarily even when passed and became unconstitutional and obsolete as the population changed. They claimed the equal protection of the laws was denied them by the "debasement of their votes." They also argued that a state constitutional amendment, or any lesser change, was difficult or impossible to get because of how the legislature was composed. They sought a declaration that the 1901 statute is unconstitutional and an injunction against further elections under it. They also asked, in the alternative, for a court-ordered reapportionment or at-large elections.

Issues

1. Does a federal district court have jurisdiction of the subject matter of a suit claiming that a state legislative apportionment denies voters the equal protection of the laws?
2. Do voters who allege that an apportionment weakens the effect of their votes have standing to sue?
3. Does a challenge to a state legislative apportionment under the Equal Protection Clause present a nonjusticiable political question, so that a court must dismiss it?

Holding

The District Court had jurisdiction of the subject matter, the voters had standing, and their equal protection claim presented no nonjusticiable political question. The complaint stated a justiciable cause of action on which the voters were entitled to a trial and a decision. The Court did not decide the merits or the remedy.