Swann v. Adams

Background

A group of voters from Dade County sued the State of Florida over the legislature’s 1966 plan for electing 48 state senators and 117 state representatives. The plan used multimember districts and produced large population differences: senate districts ranged from 87,595 to 114,053 people (about 15.09% overrepresented to 10.56% underrepresented, ratio 1.30:1), and house districts ranged from 34,584 to 48,785 people (about 18.28% overrepresented to 15.27% underrepresented, ratio 1.41:1). The federal District Court upheld the plan, finding departures from equal population not great enough to invalidate it.

Reasoning

The core question was whether the State gave acceptable reasons for those population variations. The Court explained that small deviations are allowed when justified by legitimate state policies—such as preserving political subdivisions, compact districts, or natural boundaries—but major differences need a specific, acceptable justification. The State offered no evidence explaining the large variations, while the challengers submitted an alternative plan and specific amendments showing closer equality was feasible. Because neither the State nor the lower court justified the deviations, the Court reversed the District Court’s decision.

Real world impact

The ruling requires Florida to produce a reapportionment plan that comes much closer to equal population among districts, affecting how legislative majorities may be chosen across the State. The Court did not resolve other complaints about residency rules or alleged rural/urban bias, leaving those issues for later consideration.

Dissents or concurrances

One Justice disagreed and would have affirmed. The dissent argued the State’s plan deserved a strong presumption of validity and that challengers should bear the burden of proving unconstitutionality.