Carroll v. Becker

Background

A candidate in Missouri asked a court to force the Secretary of State to accept a filing for Congress under new state-drawn districts. Congress had reduced Missouri’s number of representatives from sixteen to thirteen. The state legislature passed a redistricting bill in April 1931, but the Secretary said the Governor had vetoed that bill, so it never became law. The Missouri Supreme Court agreed and cancelled the candidate’s writ.

Reasoning

The main question was whether the state’s new district plan could be treated as valid despite the Governor’s veto. The U.S. Supreme Court found the issues were the same as in a companion case decided the same day (Smiley v. Holm) and affirmed the lower court’s judgment. In practical terms the Court accepted that the vetoed law was not effective and that, after Missouri’s reduction in seats, the old districts did not continue to exist.

Real world impact

Because Missouri now has fewer House seats and the redistricting bill was not a valid law, representatives must be chosen statewide (at large) until the State enacts a lawful district plan. The decision lets the Secretary of State refuse filings that rest on a vetoed law and leaves it to Missouri’s lawmakers to pass a valid redistricting scheme for future elections.