Parsons v. Buckley
Headline: Vermont’s legislative districting is blocked; Court approves parties’ agreement, modifies and affirms a lower-court order stopping elections under the old apportionment and sets a timetable for reapportionment.
Holding: The Court approved the parties’ stipulation, modified and affirmed the District Court’s order, and enjoined Vermont officials from holding or certifying elections under the current apportionment unless the State promptly reapportions to equalize voter weight.
- Blocks Vermont officials from certifying elections under existing district lines without prompt reapportionment.
- Forces Vermont legislature to pass reapportionment or face court-ordered redistricting.
- Allows 1964 primary and general elections to proceed under conditions, with shortened terms.
Summary
Background
A group challenging Vermont’s method of drawing legislative districts sued and the District Court held sections of the Vermont Constitution governing apportionment invalid under the Fourteenth Amendment’s guarantee of equal weighting of voters’ choices. The District Court issued an injunction preventing state and local election officials from conducting or certifying elections under the existing method unless the State adopted a lawful reapportionment. The State officials appealed to this Court, but the parties later agreed on a written plan (a stipulation) to replace part of the District Court’s order.
Reasoning
The central question was whether elections could go forward under Vermont’s existing districting when those rules were found to violate the Fourteenth Amendment’s promise of equal voter weight. The Court approved the parties’ stipulation, vacated the challenged paragraph of the lower-court judgment, substituted the agreed timetable and conditions for reapportionment, and affirmed the modified District Court judgment. The modified order allows short-term elections to proceed under strict conditions and requires the State to enact reapportionment legislation by specified dates or else face further action as spelled out in the stipulation.
Real world impact
Practically, Vermont voters, state and local election officials, and members of the legislature must follow the Court-approved timetable for reapportionment. The decision prevents officials from using the invalid district lines to certify a properly constituted General Assembly unless a constitutionally valid reapportionment occurs. The order also permits the 1964 primary and general elections to be held under specified limits and sets temporary term expirations while the State fixes its maps.
Dissents or concurrances
Justice Harlan wrote a short memorandum approving the outcome except he objected to the stipulation’s provision allowing the federal court itself to reapportion the State if the legislature failed to act, calling such court-ordered redistricting an unwelcome political undertaking.
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