Connor v. Finch

1977-05-31

Headline: Mississippi legislative maps tossed as the Court reverses and remands, finding House and Senate districts too unequal and ordering new single-member, compact districts to protect voting equality.

Holding: The Court reversed and remanded the Mississippi court-ordered House and Senate reapportionment because many districts deviated far from equal population and the court failed to justify those departures from equal-vote standards.

Real World Impact:

Forces Mississippi to redraw legislative districts with near-equal populations.
Pushes use of single-member, compact districts unless strong justification exists.
Creates urgency to fix maps before upcoming statewide elections.

Topics: redistricting, voting equality, minority representation, state legislative maps

Summary

Background

Mississippi voters and the United States challenged a federal district court’s reapportionment plan for the State’s 122-member House and 52-member Senate after years of litigation. The District Court had adopted a plan that relied in part on county lines and some multimember approaches. The challengers said the plan violated the basic rule that each legislative district should have nearly equal population and also argued it diluted Black voting strength in some places.

Reasoning

The Supreme Court examined whether the court-ordered plan met the one-person, one-vote requirement. It found the plan’s population deviations were large—about a 16.5% maximum for the Senate and 19.3% for the House—and concluded the District Court failed to justify those wide departures from equal population. The Court emphasized that court-ordered maps should generally use single-member, reasonably compact and contiguous districts and must explain any departures from near-equal population.

Real world impact

The Court reversed and sent the case back for a new or better explained plan. Mississippi must redraw its legislative districts to achieve near-equal populations or provide persuasive reasons for any departures. The Court did not decide the detailed claims about racial dilution now, but warned the District Court to avoid oddly shaped districts that could raise suspicions of minority vote dilution.

Dissents or concurrances

A concurrence stressed examining overall minority representation, while a dissent argued the District Court’s discretion should have been upheld and favored a narrower remand limited to certain districts.