Connor v. Williams

Background

A three-judge federal court found the Mississippi Legislature’s January 1971 reapportionment plan violated the Equal Protection Clause because of a total 26% population variance, and the District Court drew its own temporary plan for the 1971 elections. Those 1971 elections were held under the court’s plan. Challengers argued the court’s plan still had large variances (about 18.9% in the Senate and 19.7% in the House) and asked for the plan to be voided and new elections ordered. Mississippi has 52 Senate seats and 122 House seats; the 1970 census made the ideal single-member Senate district 42,633 people and the ideal House district 18,171 people.

Reasoning

The Supreme Court considered whether to undo the 1971 elections or require new ones. It noted prior decisions invalidating congressional maps with smaller variances do not directly control state legislative plans. The Court said that even if the court-drawn plan did not perfectly meet the Fourteenth Amendment, that alone did not automatically require canceling the 1971 elections. The Court emphasized that single-member districts are generally preferred to large multi-member districts. The District Court had retained jurisdiction and appointed a Special Master to study whether three large counties (Hinds, Harrison, Jackson) could be divided for future elections.

Real world impact

The immediate effect is that the 1971 elections stand, while the wider judgment is vacated and the case is sent back for further proceedings about later elections. About one-fifth of legislative seats (10 senators and 25 representatives) were elected from temporary multi-member countywide districts in 1971 and will be addressed in follow-up proceedings. The Court left open questions about the plan’s validity for the 1975 elections and noted the state legislature could adopt its own plan.