Do federal courts have the authority to adjudicate cases contesting state legislative districting on the grounds that it violates the Equal Protection Clause of the Fourteenth Amendment?

Tennessee voters filed a lawsuit challenging the state's apportionment statute, enacted in 1901, for violating the Equal Protection Clause. The statute had not been updated for over 60 years despite significant population shifts, resulting in substantial disparities in representation among districts. Moore County, with 2,340 voters, had the same representation as Rutherford County, which had 25,316 voters. This disparity effectively diluted the voting power of residents in more populous districts compared to those in less populous areas.

The appellants sought a declaration that the 1901 statute was unconstitutional and requested an injunction to prevent further elections under the existing apportionment until the state legislature reapportioned itself in accordance with the Tennessee Constitution. The lawsuit aimed to address the longstanding issue of unequal representation caused by the outdated apportionment statute and its failure to reflect current population distributions across the state.

Appellants initiated a lawsuit in federal district court challenging apportionment. The district court dismissed their complaint on two grounds: lack of jurisdiction and failure to state a claim. In reaching this decision, the district court relied on precedent set by Colegrove v. Green and subsequent cases, which had established that apportionment challenges were non-justiciable political questions. Dissatisfied with this outcome, the appellants exercised their right to appeal directly to the Supreme Court, bypassing the intermediate appellate court.

(Brennan, J.)

Yes. Federal courts have jurisdiction to hear and decide cases challenging state legislative apportionment on Equal Protection grounds. Such challenges present justiciable constitutional causes of action that do not fall under the political question doctrine. The Equal Protection Clause provides judicially manageable standards for adjudicating these claims, unlike cases involving the Guarantee Clause. This distinction is crucial, as it establishes a clear basis for federal court intervention in matters of state legislative districting when constitutional rights are at stake. The justiciability of these cases stems from the fundamental principle that the judiciary has a duty to protect individual rights guaranteed by the Constitution, even when doing so requires scrutiny of legislative actions. The Equal Protection Clause offers a concrete framework for evaluating the constitutionality of apportionment schemes, allowing courts to assess whether districting plans unfairly dilute the voting power of certain groups. This approach recognizes that while some aspects of the political process may be beyond judicial review, the protection of voting rights falls squarely within the purview of the courts. The decision to hear these cases does not imply any judgment on the merits of specific apportionment systems or prescribe particular remedies. Rather, it affirms the federal judiciary's role in safeguarding constitutional rights within the electoral process, ensuring that state legislatures cannot insulate potentially discriminatory practices from judicial scrutiny under the guise of political questions.

Concurrence (Douglas, J.) The right to vote is inherent in the republican form of government guaranteed by the Constitution. Federal courts must not hesitate to protect this fundamental right when infringed by state action. The judiciary has a clear duty to intervene in cases of malapportionment to safeguard democratic principles and ensure equal representation for all citizens.

Concurrence (Clark, J.) Tennessee's apportionment scheme is a 'crazy quilt' without rational basis, violating the Equal Protection Clause. The Court should have reached the merits of this case and provided guidance on fashioning an appropriate remedy. Failure to address the substantive issues leaves lower courts without clear direction in resolving similar disputes, potentially prolonging unconstitutional electoral arrangements.

Concurrence (Stewart, J.) This decision is limited to jurisdictional issues and does not address the merits of the equal protection claim or establish any specific apportionment standard. Future cases will need to determine the precise contours of constitutional requirements for legislative districting. Courts must exercise caution in this complex area, recognizing the need for flexibility in state electoral systems.

Dissent (Frankfurter, J.) The Court should not intervene in what is fundamentally a political matter best left to the legislative process. Judicial involvement in the complex issue of apportionment carries significant risks, potentially undermining the separation of powers and the Court's institutional legitimacy. The political process, not the judiciary, is the appropriate forum for resolving these inherently political disputes.

Dissent (Harlan, J.) The Equal Protection Clause imposes no limitation on a state's freedom to choose its own electoral structure. The complaint fails to state a valid claim under the Fourteenth Amendment. The majority's decision represents an unwarranted expansion of federal judicial power into an area traditionally reserved for state legislatures, threatening principles of federalism and democratic self-governance.