Colegrove v. Green

Background

Three qualified Illinois voters sued state officials (the Governor, Secretary of State, and Auditor) to stop an election under a 1901 law that fixed Congressional districts. They said population shifts left some districts far larger than others and asked a federal court to declare the law invalid and halt the election process. The District Court dismissed the complaint, and the case came here on direct review.

Reasoning

The central question was whether federal courts could order Illinois to redraw its Congressional districts or otherwise grant equitable relief. The majority held that an earlier decision (Wood v. Broom) controls and that the Reapportionment Act of 1929 imposed no requirements about compactness or equal population. The Court said the Declaratory Judgment Act did not expand equitable power to do what would effectively remake a State’s electoral system. The majority viewed the dispute as essentially political and concluded courts should not intrude when the Constitution commits regulation of elections and apportionment to legislatures and Congress. The result: the plaintiffs lost and the dismissal was affirmed.

Real world impact

Because the Court refused judicial intervention, Illinois’s existing districts remain in force unless the State Legislature or Congress acts. The ruling leaves voters without court-ordered redistricting and signals that courts will generally decline to order statewide reapportionment. The opinion also warns that judicial invalidation could produce at-large elections or legislative and House-level consequences if officials do not act.

Dissents or concurrances

Justice Rutledge joined the dismissal but emphasized restraint; Justice Black dissented, arguing the gross disparities violated voters’ federal rights and that courts should grant relief; Justices Douglas and Murphy joined his dissent.