Wells v. Rockefeller

Background

An individual challenger, Wells, sued New York state officials over the State’s 1968 law that redrew its 41 congressional districts. A three-judge federal court had approved the new map for both the 1968 and 1970 elections after striking an earlier map in 1967. The Legislature had drawn many districts by treating seven parts of the State as separate regions and making districts equal only inside those regions.

Reasoning

The Court considered whether the map violated the rule that congressional districts should represent equal numbers of people. The Justices relied on a companion decision, Kirkpatrick v. Preisler, and said equal population must be achieved across the whole State, not just within subregions. The Court found New York did not make a good-faith effort to equalize population statewide and had not justified the plan’s statewide disparities. The Court did not resolve the separate claim that the map was a partisan gerrymander.

Real world impact

The Court reversed the lower court only as to use of the 1968 map in the 1970 election and sent the case back so a new judgment can be entered. The opinion allows the 1968 election to go forward because of timing, but requires New York to adopt a constitutionally acceptable, statewide population-equal plan before the next full cycle. The decision enforces the national standard that districts must aim for equal population across the State.

Dissents or concurrances

Justice Fortas largely agreed with the result but differed on reliance on the Missouri cases. Justices Harlan and White dissented, warning the majority’s strict population rule is unduly rigid and risks excessive judicial involvement in politics.