Smiley v. Holm

Background

A Minnesota citizen, voter, and taxpayer challenged the State’s new plan to divide Minnesota into nine congressional districts. The legislature passed House File No. 1456, the Governor vetoed it, and the legislature then deposited the bill with the Secretary of State without repassing it. The challenger asked a court to stop elections held under those proposed district lines and to declare filings based on those lines invalid, arguing the bill had not become law and that it violated federal rules about compactness and equal population.

Reasoning

The central question was whether a state legislature, when prescribing the times, places, and manner of congressional elections, is performing ordinary lawmaking and therefore must follow the State’s lawmaking rules (including the Governor’s veto). The Court said yes: Article I, section 4, contemplates lawmaking power and does not override a State’s own procedures. The Court also considered earlier federal statutes and concluded that where a State’s number of representatives is reduced, new districts must be created or, until then, all representatives should be elected statewide at large. Because the Minnesota measure had not become law through the State’s required process, it could not be sustained by the Federal Constitution’s delegation alone.

Real world impact

The decision means Minnesota officials must follow the State constitution’s lawmaking steps to create valid congressional districts. If valid district lines are not in place after reapportionment, the State must elect its representatives at large until it enacts districts properly. The Court reversed the state judgment and sent the case back for further proceedings consistent with this ruling.