Court: Supreme Court of the United States; February 17, 1964; Federal Supreme Court; Federal Appellate Court
Mr. Justice Black delivered the Court's opinion regarding a case brought by appellants, citizens and qualified voters of Fulton County, Georgia, who challenged the population disparities among congressional districts in Georgia. The Fifth Congressional District, which includes Fulton, DeKalb, and Rockdale Counties, has a population of 823,680, significantly higher than the average of 394,312 for the ten districts, with one district, the Ninth, having only 272,154 residents. This disparity means that the Congressman from the Fifth District represents two to three times as many constituents as some of his counterparts, leading the appellants to claim that their voting rights under the Federal Constitution are violated. They sought to have the Georgia statute declared invalid and to enjoin the Governor and Secretary of State from conducting elections under it, alleging violations of the First and Fourteenth Amendments.
A three-judge District Court unanimously acknowledged the significant population imbalance but ultimately dismissed the complaint, citing the nonjusticiability of apportionment challenges based on a previous opinion (Colegrove v. Green) that considered such issues as 'political questions.' Judge Tuttle dissented, arguing for the justiciability of the claims based on Baker v. Carr, which recognized that disparities in state legislative districts are actionable. The Supreme Court noted probable jurisdiction and agreed with Judge Tuttle that the State's actions diminished the weight of the appellants' votes, violating their constitutional right to vote for Congress members. The Court concluded it was an error for the District Court to dismiss the suit and indicated that a declaratory judgment should have been issued.
Relief determination is deferred to the District Court based on current circumstances. The case references Baker v. Carr, which challenged a 1901 Tennessee statute for state legislative apportionment that allegedly violated the state's constitutional requirement to distribute representatives according to the number of qualified voters. The plaintiffs argued that the statute resulted in significant disparities in voter representation, thereby violating the Equal Protection Clause of the Fourteenth Amendment due to vote debasement.
The Baker Court concluded that the District Court had subject matter jurisdiction, that the Tennessee voters had standing to sue, and that the plaintiffs had a valid justiciable cause for action. These conclusions were supported by precedents from Smiley v. Holm, Koenig v. Flynn, and Carroll v. Becker, which affirmed the justiciability of congressional redistricting issues.
The Baker opinion refuted Justice Frankfurter's assertion from Colegrove v. Green that Article I, Section 4 of the Constitution granted Congress exclusive authority over voting rights, emphasizing that such an interpretation would undermine judicial protection of constitutional voting rights. The right to vote is deemed essential in a free society and deserves judicial oversight against legislative infringement. Consequently, the District Court's dismissal of the complaint was deemed erroneous.
The 1931 Georgia apportionment significantly discriminates against voters in the Fifth Congressional District, where a Congressman represents two to three times as many voters compared to Congressmen from other districts. This inequity dilutes the value of votes in the Fifth District while enhancing that of others, contradicting the principle that each vote should carry equal weight as intended by the Federal Constitution. Article I, Section 2 mandates that representatives be chosen "by the People of the several States," implying that every vote should be as valuable as any other. Historical context reveals that the Framers of the Constitution aimed for population to determine representation, whether in statewide elections or district elections. This principle underscores that allowing disparities in vote value based on district populations undermines democratic governance and the foundational concept of a House of Representatives elected by the populace. The excerpt also traces the evolution from the Continental Congress through the Articles of Confederation to the Constitutional Convention of 1787, highlighting the need for a stronger federal government to address the inadequacies of the previous system and ensure fair representation.
Edmund Randolph of Virginia proposed a new National Government at the Convention, featuring a National Executive, National Judiciary, and a bicameral National Legislature. The structure of the legislature sparked intense debate, particularly regarding equal representation for voters regardless of their state. George Mason and James Madison championed the idea that each voter should have an equal voice in electing Congress members, arguing against the unfairness of equal representation for states of different populations. Madison stressed that power must be derived from the people proportional to their numbers.
Opposition arose, particularly from smaller states like Delaware, who feared domination by more populous states if representation were based solely on population. William Paterson of New Jersey argued for maintaining equal state sovereignty as per the Articles of Confederation, proposing a single legislative chamber with equal votes for each state. Delegates favoring equal voting strength criticized this approach, labeling it unjust. The debate nearly derailed the Convention, with tensions escalating to the point where some delegates threatened to withdraw. Benjamin Franklin intervened, urging compromise to prevent a breakdown of discussions. Ultimately, a reconciliation was reached between those advocating for proportional representation and those supporting equal state votes.
The deadlock among the States was resolved through the Great Compromise, proposed by Roger Sherman and others from Connecticut. This compromise established that each State would have two Senators, elected by state legislatures, ensuring equal representation in the Senate, as outlined in Article I, Section 3, and Article V. In contrast, the House of Representatives would be elected directly by the people of the States, with representation apportioned based on population, as specified in Article I, Section 2. The delegates emphasized that the House should represent individuals, determined solely by the number of inhabitants, rejecting any wealth-based apportionment. Edmund Randolph's proposal for a periodic census to maintain fair representation was accepted, and a motion to limit representation from newer Western States was defeated to uphold the principle of equal representation based on population. The delegates aimed to avoid the "vicious representation" seen in Great Britain, where underpopulated areas had disproportionate representation. Madison noted that congressional districts should be formed based on population numbers, asserting that numbers provide the appropriate scale for representation. During the state conventions, proponents of the Constitution highlighted the importance of equal representation in the House, reinforcing its commitment to representing individual rights.
Speakers at the ratifying conventions stressed that the House of Representatives should avoid the malapportionment present in some state legislatures, advocating for Congress's power under Article I, Section 4 to ensure equal representation. John Steele argued against the creation of "rotten boroughs" and indicated that Congress would likely establish districts while emphasizing the role of independent judges to uphold constitutional laws. James Wilson, reflecting on the Constitutional Convention, asserted that elections should be equal, ensuring that citizens in different state regions have the same representation. This historical context guides the interpretation of Article I, Section 2, which mandates that representatives be chosen by the people and apportioned based on population. The Court has recognized a constitutional right to vote, reaffirming that this right cannot be denied, altered, or diluted. Madison's Federalist No. 57 reinforces that all citizens, regardless of wealth or status, are entitled to vote, suggesting a principle of one person, one vote. While precise congressional districting may be challenging, the Constitution prioritizes equal representation. The document concludes by referencing the complexities of political questions and the Court's discretion in providing equitable relief, while noting the Constitution's provision for states to regulate elections, subject to Congressional oversight.
