Lucas v. Rhodes

Background

A group of Ohio voters challenged the State’s 1964 congressional map. They argued some districts were much larger or smaller than the average—about 13% above and 18% below—based on the 1960 census. State officials said the Legislature had used unofficial, more recent population figures for some counties to correct those differences. A federal trial court accepted that explanation, but the issue was appealed upward.

Reasoning

The Supreme Court issued a short, unsigned decision that reversed the lower judgment and sent the case back to the District Court for further proceedings. The central legal yardstick in dispute was the rule from an earlier case that, as nearly as practicable, each person’s vote for Congress should carry the same weight. Lower courts had disagreed about whether the State could rely on unofficial, post‑census population numbers and whether the map’s percentage deviations were acceptable. Justice Harlan, joined by Justice Stewart, dissented and argued the District Court should be affirmed because the State had shown population shifts since 1960 and strict mathematical equality is not required.

Real world impact

The ruling does not decide finally whether Ohio’s map is constitutional. Instead, it sends the challenge back so the District Court can take another look, including any evidence about population changes and which data to use. That means Ohio voters and election officials face continued uncertainty about congressional district lines and possible further litigation or adjustments.

Dissents or concurrances

Justice Harlan’s dissent says the map was not shown unconstitutional, stresses that perfect numerical equality is unnecessary, and would have left the District Court’s decision in place.