J. Brian Gaffney v. Theodore R. Cummings Mark White, Jr. v. Diana Regester
Headline: Court upholds Connecticut and Texas legislative districting despite population inequalities, but bars Texas multimember districts in Dallas and Bexar that diluted minority votes, allowing wider tolerances for state plans.
Holding: The Court upheld Connecticut’s and Texas’s state legislative apportionment plans despite population deviations, but struck down multimember districts in Dallas and Bexar for diluting minority votes.
- Allows states to keep larger population variances without offering detailed justification.
- Affirms that multimember districts that dilute minority votes can be invalidated.
- Makes it harder for courts to force strict mathematical equality in every plan.
Summary
Background
Connecticut and Texas adopted new plans for electing state legislators after the 1970 census. Connecticut’s plan set up 151 single-member districts with an ideal district population of 20,081, but many districts varied and the total spread was 7.83%. Plaintiffs offered alternative maps with much smaller deviations. In Texas the House plan used 79 single-member and 11 multimember districts with an ideal of 74,645 people and a total deviation reported as at least 9.9% (arguably larger depending on calculation).
Reasoning
Lower federal courts had found both state plans invalid because the population deviations were not justified by any legitimate state interest. The Supreme Court overturned those holdings and upheld the statewide plans, reasoning that total deviations below a certain level do not by themselves prove unconstitutional discrimination. The Court did, however, affirm the lower court’s finding that the use of multimember districts in Dallas and Bexar Counties had the unconstitutional effect of minimizing the voting strength of racial groups.
Real world impact
The decision lets these particular Connecticut and Texas plans stand despite measurable population inequalities, reducing the need for states to justify every small deviation from exact equality. At the same time, it confirms that districting devices that dilute minority voting strength, like certain multimember districts, can be struck down. The practical result is broader breathing room for state mapmakers but continued protection against racial vote dilution.
Dissents or concurrances
Justice Brennan dissented in part, arguing the Court’s approach departs from earlier decisions that required states to justify deviations and warned this ruling would weaken equal-vote protections.
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