Wesberry v. Sanders (1964)
Case Summary
Wesberry, a voter of the 5th District of Georgia, filed suit on the basis that his Congressional district had a population 2-3 times larger than other districts in the State, thereby debasing his vote. Plaintiffs sought an injunction to prevent any further elections until the legislature had passed new redistricting laws to bring the districts in line with population distribution. The case was dismissed at the district level, but reached the Supreme Court on appeal.
Ruling
The Court found that, as in Baker, the malapportionment of districts gave plaintiffs standing and presented a justiciable issue. The Court further found that Section 2, Article 1 of the Constitution requires that, to the extent possible, one person’s vote should be equal to any others when electing Representatives of Congress. Specifically, Justice Black’s majority opinion determined that the clause “by the People of the several States” “means that as nearly as is practicable one man’s vote in a congressional election is to be worth as much as another’s.” The differences between Georgia’s districts thus represented a violation of this principle. The case was reversed and remanded, with the Supreme Court explicitly electing not to address “the arguments that the Georgia statute violates the Due Process, Equal Protection, and Privileges and Immunities Clauses of the Fourteenth Amendment.”
Impact on Redistricting
Wesberry was a significant step in the evolution of redistricting law that followed Baker, further establishing the idea that districts were to be as equal as possible and setting the stage for the later refinement of the one-man one-vote principle. In response to the case, districts across the country had to be redrawn to provide more equitable representation, a process which in some instances had significant political ramifications. The case also served as a predecessor to the series of cases known collectively as the “Reapportionment Cases,” which would go beyond Federal elections to dramatically change the landscape of State legislative elections as well.