Brief Fact Summary. By failing to reapportion seats for its legislature for 60 years, Alabama’s voting scheme permitted a minority of the people in the State to elect a majority of the State’s lawmakers.
Synopsis of Rule of Law. The Equal Protection Clause of the United States Constitution (Constitution) requires that the seats in both houses of a bicameral state legislature be apportioned on a population basis.
Facts. Alabama failed for over 60 years to reapportion seats for the Alabama Legislature. This resulted in a scheme by which a minority of the people in the State could elect a majority of the State’s legislators.
Issue. Was Alabama’s apportionment scheme in violation of the Equal Protection Clause of the Fourteenth Amendment of the Constitution?
Held. Yes.
Chief Justice Earl Warren (J. Warren) stated the right to vote is personal in nature and fundamental in a free democratic society. Therefore, any impairment of such a right calls for “meticulous scrutiny”.
It could not be argued that a system in which citizens in one part of the State are given two times, five times, or ten times the weight of the citizens in other part was consistent with Equal Protection. Yet, the statute at issue here is in effect identical.
Dissent.
Justice Harlan (J. Harlan) argued that the Fourteenth Amendment of the United States Constitution (Constitution) was not intended to limit the power of the States to apportion their legislatures as they saw fit. It is hard to imagine a more intolerable interference by the judiciary with the independent legislatures of the States.
Justice Potter Stewart (J. Stewart) stated that what constitutes a rational plan reasonably designed to achieve a fair, effective, and balanced representation of the regional, social and economic interests within the States is best left to the States.
Discussion. This case introduces us to the “one person, one vote” theory of constitutional law.