Wesberry v. Sanders

1964-02-17
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Headline: Court requires congressional districts to have nearly equal populations, striking down Georgia’s lopsided map and making individual U.S. House votes carry roughly equal weight.

Holding:

Real World Impact:
  • Requires states to draw congressional districts with roughly equal populations.
  • Makes individual votes for U.S. House districts roughly equal in weight.
  • Authorizes federal courts to review and invalidate lopsided congressional maps.
Topics: congressional redistricting, voting equality, one person one vote, court review of maps

Summary

Background

A group of qualified voters in Fulton County, Georgia challenged the State’s 1931 law that divided Georgia into ten congressional districts. The Fifth District around Atlanta had 823,680 people by the 1960 census while the state average was about 394,312, meaning some districts contained two to three times as many residents as others. The voters sued the Governor and Secretary of State, saying the scheme diluted their votes for the U.S. House and asking courts to block elections under that map. The three-judge District Court found the Fifth District “grossly out of balance” but dismissed the complaint; the case went to the Supreme Court.

Reasoning

The Supreme Court asked whether Article I, §2 and the Constitution’s history require that congressional districts give each voter roughly equal weight. The majority relied on the text and debates from the Constitutional Convention and concluded that Representatives must be chosen “by the People” in a way that makes one person’s vote as nearly equal in weight as practicable. The Court reversed the dismissal, held the Georgia plan violated that principle, and sent the case back to the District Court to consider appropriate relief.

Real world impact

The ruling means states must draw U.S. House districts with roughly equal populations, or risk having their maps struck down in court. It extends judicial protection to the weight of congressional votes, not just state legislative contests. The decision did not set a single precise numeric standard and left remedies to lower courts and legislatures, so practical adjustments and further litigation were expected.

Dissents or concurrances

Justice Clark concurred in part and dissented in part, urging a merits hearing under equal protection; Justice Harlan dissented, warning the Court was overstepping and that Congress and state legislatures control apportionment. Justice Stewart agreed with Harlan’s view that the Constitution does not command exact equality.

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