Chapman v. Meier
Headline: Court limits federal courts’ power to impose multimember state legislative districts, reverses North Dakota plan with large population variances, and orders single-member districts and near-equal populations unless strong state reasons exist.
Holding: The Court reversed the three-judge District Court, holding that a court-ordered state legislative reapportionment must ordinarily use single-member districts and achieve near-equal population unless the court explains persuasive state reasons.
- Requires federal courts to prefer single-member districts in court-ordered plans.
- Court-ordered plans must achieve near-equal population with only de minimis variation.
- Leaves primary reapportionment responsibility with state legislatures to act promptly.
Summary
Background
Citizens of North Dakota sued state officials, including the Secretary of State, after a long series of reapportionment disputes. The State had used an old 1931 plan, a federal court drew a 1965 plan, and later a three-judge federal court approved a court-crafted plan with five multimember senate districts and substantial population deviations following the 1970 census.
Reasoning
The central question was whether a federal court may impose multimember state legislative districts and tolerate large population differences among districts. The Court held that when a federal court itself fashions a state legislative plan it should ordinarily prefer single-member districts and achieve near-equal population across districts. Large variances require persuasive, articulated state reasons. Because the District Court kept multimember senate districts and accepted about a 20% population spread without adequate justification, the Supreme Court reversed and sent the case back for further proceedings.
Real world impact
The decision tells lower federal courts to avoid imposing multimember legislative districts and to aim for very small population differences in court-drawn plans unless there is a clear, compelling state policy explaining otherwise. It also reiterates that reapportionment is primarily the State Legislature’s duty, and that courts should act only when the State fails to do so.
Dissents or concurrances
The lower-court dissents argued that multimember districts might be a practical choice for elections and that decisions about district types are for state legislatures, not judges. Those views influenced but did not carry the judgment below.
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