Baker v. Carr (1962)
Case Summary
Charles Baker, a resident of an urban neighborhood in Tennessee, filed suit in federal court against Joe Carr, then Secretary of State of Tennessee. Baker sought a court injunction to postpone elections until the State had fulfilled its duty to reapportion its legislative districts, which it had not done since 1901 (over 60 years). Though the Tennessee Constitution required that reapportionment be carried out every ten years, Baker’s claim was based on the 14th Amendment’s Equal Protection Clause. Baker argued that because of population changes in the state, specifically migration to cities, his vote in an urban area had much less weight than that of a voter in a rural district, thus constituting a “debasement of [his] votes.”
Ruling
After being dismissed at the district court level, the case was taken on appeal by the Supreme Court, which reversed the ruling, deemed the issue justiciable, and remanded. The Court found that plaintiffs had standing to sue, referencing Colegrove v. Green as precedent for granting “voters who allege facts showing disadvantage to themselves as individuals… standing to sue.” Reversing Colegrove, however, the Court went on to find that the courts were an appropriate source of relief for cases involving malapportionment. A major question before the Court was the issue of the political question doctrine, by which the district court and the Colegrove court had ruled issues involving reapportionment as nonjusticiable. The Supreme Court reversed, determining that because the claims were not derivative of the Guaranty Clause of Article IV, but rather the 14th Amendment, that simply the implication of political rights did not render an issue inappropriate for judicial review. While the Court created a six-part test to determine if a case presented a political question, the most important fact for redistricting purposes was the determination that the voting inequities presented satisfied these requirements, including the judgment that courts can provide “discoverable and manageable standards” for granting relief.
Impact on Redistricting
Baker v. Carr opened the door to judicial review of the redistricting process, prompted a cascade of subsequent lawsuits, and sent shockwaves through the redistricting community. Though the opinion stopped short of addressing the shape relief should take in malapportionment cases, by recognizing unequal districts as creating real and justiciable injuries, it laid the groundwork for the rapid development of the “one-person one-vote” principle. It is no coincidence that by 1964, only two years later, 26 States had reapportioned their legislative districts, three under court-drawn plans, many more under judicial pressure. By 1966 that number rose to 46 states.