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Baker v. Carr

Supreme Court of the United States · 1962 · Constitutional Law

political question doctrinestandingreapportionmentjusticiabilityEqual Protectionpolitical questionjusticiablestanding

Facts

The plaintiffs were qualified voters residing in several Tennessee counties who alleged that Tennessee was still using a 1901 apportionment statute to allocate seats in the General Assembly despite substantial population growth and redistribution since 1901. They claimed this continued use debased their votes and denied them equal protection because representation no longer tracked the State's constitutional standard based on qualified voters. The complaint also alleged that the 1901 statute had been arbitrary even when enacted and had become unconstitutional and obsolete because the legislature had failed to reapportion itself for more than sixty years. The plaintiffs sought declaratory and injunctive relief against future elections under the statute, plus further relief if the legislature failed to enact a valid reapportionment.

Issue

Whether a federal court has jurisdiction over, and may adjudicate, an Equal Protection challenge by state voters to a state's legislative apportionment scheme, or whether such a claim presents a nonjusticiable political question. The Court also addressed whether the plaintiffs had standing to bring the suit.

Rule

A claim that state legislative apportionment debases votes in violation of the Equal Protection Clause presents a case arising under the Constitution, is within federal jurisdiction under 28 U.S.C. § 1343(3), and is justiciable unless it involves one of the defining characteristics of a political question. Political questions are marked by factors such as a textually demonstrable constitutional commitment to another branch, lack of judicially discoverable and manageable standards, the need for an initial policy determination of a kind for nonjudicial discretion, lack of respect due coordinate branches, unusual need for adherence to a political decision already made, or potential embarrassment from multifarious pronouncements by different branches.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Voters from Phoenix, Tucson, and Flagstaff sue Arizona election officials in federal district court under 42 U.S.C. § 1983. They allege that an unchanged legislative districting statute now grossly dilutes their votes in violation of the Equal Protection Clause because population has shifted dramatically among counties and districts.

The state moves to dismiss for lack of subject-matter jurisdiction, arguing that legislative districting is inherently political. How should the court rule?

Explanation. The majority held that when a complaint plainly alleges deprivation of equal protection by state action, the case arises under the Constitution. Dismissal for lack of subject-matter jurisdiction is proper only if the federal claim is wholly insubstantial or frivolous. The fact that the dispute concerns legislative apportionment does not itself defeat jurisdiction.