Wood v. Broom
Headline: Decision allows Mississippi to use its seven-member congressional map, reversing a lower court and ruling older federal districting rules from 1911 do not limit the 1929 reapportionment.
Holding: The Court held that the 1911 statute’s districting requirements expired with the apportionment they governed and were not carried into the 1929 reapportionment, so Mississippi’s seven-district plan must be upheld and the injunction reversed.
- Allows Mississippi to hold elections using its seven new congressional districts.
- Means the 1911 compactness rules do not constrain the 1929 reapportionment.
- Ends the federal injunction blocking the state’s redistricting plan.
Summary
Background
A Mississippi citizen who said he was a qualified voter and candidate sued state officials after the Legislature drew seven congressional districts following a loss of one seat. He argued the new map violated the Constitution and a 1911 federal law that he said required districts to be compact, contiguous, and of nearly equal population. A three-judge District Court blocked the map and entered a permanent injunction, and the state appealed.
Reasoning
The central question was whether the 1911 law’s districting rules still applied to the reapportionment made by Congress in 1929. The Supreme Court examined the text and lawmaking history and concluded those 1911 requirements were tied to the earlier apportionment and expired with it. Because the 1929 law intentionally omitted those rules, the Court held they did not govern the districts drawn under the 1929 reapportionment, and the District Court’s injunction was incorrect.
Real world impact
The practical result is that Mississippi may proceed with elections using the seven districts drawn by the state Legislature. The plaintiff’s challenge was reversed and the complaint ordered dismissed, so the federal court will not enforce the 1911-style compactness and equality rules against this 1929-based plan. The ruling rests on statutory interpretation of those federal laws, not on resolving all constitutional claims.
Dissents or concurrances
Four Justices agreed the decree should be reversed but would have dismissed the case on procedural equity grounds without deciding whether the 1911 statute applied.
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