Baker v. Carr
Deciding whether redrawing voting districts could be adjudicated or whether it was an issue strictly for state legislatures turned out to be a very challenging issue for the U.S. Supreme Court. When the court was asked to hear the matter of Baker v. Carr in 1961 the arguments and decision-making process took a year and split the court.
In the end the court’s decision became known as the “one person one vote” rule that had wide-reaching implications for states. The precedent it struck down was Colegrove v. Green, a similar case in which the Court decided redistricting was better left to state legislatures. Its position was further fleshed out in the 1964 decision on redistricting, Reynolds v. Sims.
Another impact of the case was the concept of justiciability – the means for determining if the court should be involved in the decision-making. The court is always cautious of overstepping its boundaries as the final arbiter on the constitutionality of state laws, making this test of its ability and need to weigh in on a situation a touchstone for future decades.
At issue was the state of Tennessee’s noncompliance with the state constitution that required legislative districts to be redrawn every 10 years with the release of Census data. In 1960 the districts hadn’t been reconfigured since 1900, and the metropolitan area around Memphis, where plaintiff Charles Baker was a resident. He complained that the state’s inaction on redistricting deprived him of his Fourteenth Amendment rights to equal protection and sued Secretary of State Joe Carr.
In its decision members of the Court switched from concurrence to dissent, eventually splitting 6-2 in favor of remanding the case to District court.
The standard for justiciability or limits to judicial discretion that emerged from the case involved a checklist of six ways to test whether a case should involve the court or a state legislature, including whether a decision requires a policy determination by the court on behalf of a state legislature and finding the constitutional justification for interceding in an issue that can be left to states to resolve.