Supreme Court Decision
Baker v. Carr
The Baker case, seemingly a fairly simple issue of voting rights, had a variety of levels, including a very complicated argument over Judicial Review, which we'll only touch lightly.
On its best remembered level, Baker was the forerunner of a case heard the following year, Gray v. Sanders, which would establish the doctrine of one person one vote. Baker did not go quite that far, though Chief Justice Earl Warren called it the "most vital decision" during his term on the high court. If this is a little exaggerated, the case nevertheless was a crucial moment in the key area of voting rights.
At issue in Baker was a suit by a variety of urban Tennessee voters that the state's redistricting plan -- calling for a reapportionment among its counties with every decennial census -- was arbitrary and weighted against urban voters. Compounding the issue was the fact that the state had not carried out a formal reapportionment since 1901.
The plaintiffs in the case had had no relief from Tennessee authorities or state courts, and the federal courts found that they had neither constitutional jurisdiction in the issue, nor was it justiciable, i.e. it could not or should not be resolved by the judiciary, being a political issue. So the suit was brought directly to the Supreme Court.
The high court was divided over the issue of justiciability, with Justice Frankfurter reminding them of a recent squeaker of a case, Colgrove v. Green, wherein the Court had refused to interfere in redistricting problems in Illinois, calling them a "political thicket". But Justice William Brennan, writing for the Court in the current case, had no difficulty with the jurisdiction issue, and very little with the question of justiciability. Instead he found that the plaintiffs had sufficient interest in the value of their votes to have standing before the Court, and that the larger issue of Equal Protection of the Laws expressed in the Fourteenth Amendment made it imperative that the Court invest itself in such cases.
Brennan concluded that the "denial of equal protection [of the laws] present[s] a justiciable constitutional case of action upon which appellants [the plaintiffs in this case] are entitled to a trial and a decision." Basically the Court decided that the Baker plaintiffs could go back to federal court and pursue their lawsuit against the state of Tennessee. The Court also indicated that Tennessee's failure to abide by its own constitution in reapportioning voting districts should not limit the scope of the decision, but that any state whose apportionment methods fail to show a "rational basis" is open to suit by effected voters.
In their dissents, Justices Harlan and Frankfurter expressed concern that this decision would interpret the Equal Protection Clause as requiring mathematically precise vote distribution (which in fact did become the interpretation in Gray), and that the federal courts were opening themselves to involvement in an arena which has since "time out of mind" been determined by an "essentially political conflict of forces…"
Although the doctrine of one person one vote seems ultimately to be the proper interpretation of the Constitution, setting aside the purely practical concerns of constantly maintaining such a precise balance, Justice Harlan made a valuable observation when he suggested that it may not be so wrong for a state like Tennessee to use apportionment to insure that less populous rural areas maintain a sufficiently strong voice in government.
In any event, Baker opened the floodgates for voter suits against the states, with thirty-six states finding themselves defendants in such suits within a year. The barrage forced the Court to abandon the somewhat loose concept of "rationality" and adopt mathematical apportionment in Gray.
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Other decisions pertaining to Representation:
Betts v. Brady [316 U.S. 455 (1942)] Stone Court
Gideon v. Wainwright [372 U.S. 335 (1963)] Warren Court
Gray v. Sanders [372 U.S. 368 (1963)] Warren Court
Grovey v. Townsend [295 U.S. 45 (1935)] Hughes Court
Reynolds v. Sims [377 U.S. 533 (1964)] Warren Court
Wesberry v. Sanders [376 U.S. 1 (1964)] Warren Court