Sixty-Seventh Minnesota State Senate v. Beens

1972-04-29

Headline: Minnesota legislative reapportionment: Court blocks federal judge’s plan to cut state senate and house sizes, restores state’s statutory numbers and sends the case back for prompt, state-aligned proceedings.

Holding: The Court vacated the district court’s drastic reapportionment, held that federal courts may not slash a State’s prescribed legislative size absent necessity, and returned the case to the district court to proceed consistent with state law.

Real World Impact:

Keeps Minnesota's current statutory senate and house numbers intact for now.
Limits federal courts from drastically cutting state legislative size absent clear necessity.
Requires prompt district-court action to ensure 1972 elections proceed under valid plan.

Topics: legislative reapportionment, state elections, court power over legislatures, voting equality

Summary

Background

Three Minnesota voters sued, saying the state's 1966 plan gave voters unequal weight after the 1970 census. A three-judge district court agreed the plan was unconstitutional, invalidated the 1966 apportionment law, and adopted a court-drawn plan reducing the senate from 67 to 35 districts and cutting representatives as well. The Minnesota State Senate intervened and appealed. The Governor had vetoed a legislative reapportionment passed in late 1971, so the 1966 law remained on the books while 1972 elections loomed.

Reasoning

The central question was whether a federal court could change the number of state legislative seats or must respect the state's statutory choice of size. The Supreme Court held the district court went too far: courts may remedy unconstitutional apportionment but should, insofar as possible, accommodate state statutes that fix legislature size. The Court found the 1966 statutes specifying 67 districts and set member counts were severable and not invalidated, and that a near-halving of the senate and major reduction of the house was not justified. The Court vacated the district court's orders and remanded for further proceedings consistent with state law.

Real world impact

The decision preserves Minnesota's statutory numbers for now and requires the district court to act quickly so elections can proceed. It limits federal courts from radically changing a State's chosen legislative size absent clear necessity. The ruling leaves room for minor adjustments when needed and does not prevent the State legislature from enacting a new plan.

Dissents or concurrances

Justice Stewart dissented, arguing the district court had broad equitable power to craft a remedy and that summary reversal was premature without the full record; he would not say the three-judge court abused its discretion in reducing size.