Swann v. Adams

Background

This case began in 1962 when challengers sued over Florida’s legislative apportionment. After Reynolds v. Sims required new reapportionment rules, the District Court waited for the Florida Legislature’s 1965 session, which convened April 6, 1965. The Legislature passed a reapportionment law on June 29, 1965. On July 6 the challengers asked the District Court to declare that plan unconstitutional and offered an alternative. The District Court held arguments later in 1965 and on December 23 concluded the plan violated the Equal Protection Clause, yet approved the plan on an interim basis with a time limit tied to the 1967 legislative session.

Reasoning

The key question was whether the District Court properly allowed a plan it found constitutionally deficient to remain temporarily in force. The Supreme Court noted Florida had conceded the plan’s constitutional defects and said there was no reason to let an unconstitutional map persist for another three years. The Court ruled the District Court erred by approving the interim plan and reversed, directing that a valid reapportionment be made effective for the 1966 elections.

Real world impact

The decision requires Florida to put a constitutionally valid legislative map in place for the 1966 elections, affecting how voters are grouped and represented. It prevents the continuation of a map the courts already found deficient and speeds the timing of reapportionment relief. Because the Court reversed the interim approval, the change is intended to affect immediate upcoming elections rather than wait until 1969.

Dissents or concurrances

Two Justices, Harlan and Stewart, said they would have affirmed the District Court’s judgment. Justice Fortas did not participate in the decision.