Whitcomb v. Chavis

1971-06-07

Headline: Ruling lets Indiana keep countywide multi-member elections for Indianapolis-area seats, rejects lower court’s blanket invalidation, and affirms courts may require statewide redistricting that alters who elects state legislators.

Holding: The Court ruled that the federal trial court wrongly struck down Marion County’s multi-member legislative district under the Equal Protection Clause, holding multi-member districts are not per se unconstitutional while approving statewide reapportionment as appropriate.

Real World Impact:

Keeps multi-member countywide elections from being automatically struck down.
Allows federal courts to order statewide redistricting to fix malapportionment.
Leaves affected communities able to press future claims using new evidence.

Topics: voting rights, legislative redistricting, racial discrimination, multi-member districts

Summary

Background

Six Indiana residents (five from Marion County, including Black residents of a Center Township ‘‘ghetto’’ area) sued, saying Marion County’s system of electing many state senators and representatives at large diluted their votes and left the neighborhood underrepresented. A three-judge federal court found an identifiable racial minority with distinct needs, held the countywide multi-member system canceled their voting strength, and ordered single-member districts statewide.

Reasoning

The Supreme Court addressed whether multi-member countywide elections are automatically unconstitutional or whether the challengers had to prove they produce invidious vote-dilution in practice. The majority said multi-member districts are not per se illegal. The Court concluded the trial record did not show that the Black ghetto was denied access to normal political processes or that the county delegation actually had greater decisive influence; accordingly the trial court erred in broadly invalidating Marion County’s multi-member scheme. At the same time the Court agreed the district court was justified in ordering statewide reapportionment to correct large population disparities.

Real world impact

The decision means Indiana’s multi-member law was not automatically voided by this case, but federal courts can still require new maps when population imbalances or proven dilution exist. Marion County residents, Black community groups, and statewide officials are affected because the case was reversed and remanded for further proceedings while the Court recognized that statewide redistricting can be appropriate to remedy malapportionment. The Court noted the controversy was not moot even though the state later adopted single-member districts.

Dissents or concurrances

Justices wrote separately: one Justice sharply criticized this Court’s voting cases, and another argued the trial court was correct and would have affirmed the district court’s redistricting order to protect the minority group.