When Charles Baker filed his complaint in federal court challenging Tennessees voting district lines, Americans had been moving from rural areas into cities since the turn of the century. Despite this population shift, many state legislatures refused to redraw voting district lines, thereby keeping power in the hands of rural voters. Baker, who lived in Memphis, challenged this practice, saying that rural votes were effectively worth more than urban votes because rural areas had, per person, more representatives than urban areas. Baker argued that this violated his right to equal protection as required by the 14th Amendment.
The Supreme Court would not have been able to rule on this case if it involved a political question. In determining that reapportionment was not a political question, the Court crafted a six-part test to determine if issues are political in nature.
Chief Justice Earl Warren called the Baker opinion the most important in his tenure. In the nine months after the Court's decision, reapportionment cases were brought challenging district lines in 34 states. The cumulative effect of these and similar cases was to reshape the country's political landscape.
369 U.S. 186 (1962)
APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE
Appellants are persons allegedly qualified to vote for members of the General Assembly of Tennessee representing the counties in which they reside. They brought suit in a Federal District Court in Tennessee under 42 U.S.C. § § 1983 and 1988, on behalf of themselves and others similarly situated, to redress the alleged deprivation of their federal constitutional rights by legislation classifying voters with respect to representation in the General Assembly. They alleged that, by means of a 1901 statute of Tennessee arbitrarily and capriciously apportioning the seats in the General Assembly among the State's 95 counties, and a failure to reapportion them subsequently notwithstanding substantial growth and redistribution of the State's population, they suffer a "debasement of their votes," and were thereby denied the equal protection of the laws guaranteed them by the Fourteenth Amendment. They sought, inter alia, a declaratory judgment that the 1901 statute is unconstitutional and an injunction restraining certain state officers from conducting any further elections under it. The District Court dismissed the complaint on the grounds that it lacked jurisdiction of the subject matter and that no claim was stated upon which relief could be granted.
1. The District Court had jurisdiction of the subject matter of the federal constitutional claim asserted in the complaint. Pp. 369 U. S. 198-204
2. Appellants had standing to maintain this suit. Pp. 369 U. S. 204-208.
3. The complaint's allegations of a denial of equal protection presented a justiciable constitutional cause of action upon which appellants are entitled to a trial and a decision. Pp. 369 U. S. 208-37.
179 F.Supp. 824, reversed and cause remanded