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Colegrove v. Green

Supreme Court of the United States · 1946 · Constitutional Law

Constitutional LawPolitical Question DoctrineCongressional DistrictingJusticiabilityEquitypolitical questionjusticiabilityequity

Facts

Petitioners were qualified Illinois voters residing in congressional districts with much larger populations than other Illinois districts. They sued the Governor, Secretary of State, and Auditor of Illinois, acting as the Illinois Primary Certifying Board, to prevent the 1946 election from proceeding under the congressional districts established by Illinois law in 1901. They alleged that subsequent population changes had made those districts noncompact and grossly unequal in population, violating the United States Constitution and the federal reapportionment statute. The district court dismissed the complaint as controlled by Wood v. Broom.

Issue

May federal courts grant declaratory or injunctive relief against state officials on the ground that a state's congressional districts have become grossly unequal in population and unfairly configured, or is that controversy committed to the political branches and therefore not fit for judicial determination?

Rule

Federal courts lack authority to grant equitable or declaratory relief when the claim asks the judiciary to reconstruct a state's congressional districting system and the controversy is of a peculiarly political nature committed by the Constitution to Congress. The Declaratory Judgment Act does not enlarge the substantive scope of equitable relief; the controversy must be one that would be justiciable in a suit for injunction under established equitable principles.

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

Three voters in Ohio sue the secretary of state in federal court, alleging that the state’s congressional districts have not been redrawn in decades and now contain wildly unequal populations. They seek an injunction stopping the upcoming congressional election unless the legislature adopts a new district map.

How should the federal court rule under the governing majority approach?

Explanation. The majority treated this type of challenge as a demand that federal courts enter the 'political thicket' by reconstructing a state’s system for electing Representatives. Because Article I leaves regulation of congressional elections and correction of unfairness to Congress, and the House judges its members, the controversy is of a peculiarly political nature and not fit for judicial determination. The court therefore should dismiss rather than enjoin the election.