Baker v. Carr

This case made it possible for unrepresented voters to have their districts redrawn by federal courts, initiating a decade of lawsuits that would eventually result in a redrawing of the nation's political map. In many states it reduced the disproportionate power of rural voters and their legislative representation and increased that of urban and suburban voters and their representation.

Citizens of Memphis, Nashville, and Knoxville, Tennessee, sought to have their electoral districts redrawn. The districts had not been reapportioned since 1901, and since then a considerable population shift had taken place from rural to urban locales. The result was that residents of these cities felt they were being underrepresented in the state legislature in violation of the equal protection guarantees contained in the Fourteenth Amendment. The U.S. District Court for the Middle District of Tennessee declined to grant the plaintiffs' request that a declaratory judgment be issued indicating that the Tennessee apportionment act was unconstitutional, and that an injunction be issued to prevent state officials from conducting further elections using the existing electoral district boundaries. Instead, the court found the voters' complaint to be a "political question" which courts could not decide and which, furthermore, was outside the scope of the authority conferred on the judiciary by Article III of the Constitution. Such matters were the province of the legislative branch. When the district court dismissed their case against Joe C. Carr, the Tennessee Secretary of State, Charles Baker and his fellow appellants appealed their case directly to the U.S Supreme Court.

This procedure for getting to the Supreme Court was by this date unusual, and everyone involved in the case recognized that everything about it was extraordinary. Various parties, including the solicitor general, filed amicus briefs, and the Court heard three hours of oral argument, permitting the attorneys to present their case at far greater length than is normally allowed. After this initial argument on 19-20 April 1961, the case was reargued on 9 October 1961 before the justices released five opinions totalling 163 pages.

The Court divided 6-2, with Justice Brennan delivering the opinion of the majority. He dispensed with the argument that the case involved a political question which the Court could not decide: "The courts cannot reject as `no law suit' a bona fide controversy as to whether some action denominated as `political' exceeds constitutional authority." And in the end, the Court found that the appellants' claim had merit:

We conclude that the complaint's allegations of a denial of equal protection present a justifiable constitutional cause of action upon which appellants are entitled to a trial and a decision. The right asserted is within reach of judicial protection under the Fourteenth Amendment.

The Court sent the case back to the federal district court for further proceedings.

The consequences of this potential outcome had been clear from the start. Now Justice Brennan's opinion cast doubt on legislative districting throughout the country. Indeed, within a decade, electoral boundaries had been redrawn everywhere. Baker v. Carr, which Chief Justice Warren called "the most vital decision" handed down during his long and eventful tenure on the Court, started a reapportionment revolution that helped to establish the "one person, one vote" precept formally announced in Gray v. Sanders (1964) and confirmed in Wesberry v. Sanders (1964) and Reynolds v. Sims (1964). Now that voters had access to federal courts, they had the power to enforce the principle of equal protection under the laws that the Fourteenth Amendment had codified nearly 100 years before.