Baker v. Carr

Charles W. Baker and other Tennessee citizens alleged that a 1901 law designed to apportion the seats for the state’s General Assembly was virtually ignored. Baker’s suit detailed how Tennessee’s reapportionment efforts ignored significant economic growth and population shifts within the state.

Rule:

A federal court cannot pronounce any statute, either of a state or of the United States, void, because it is irreconcilable with the United States Constitution, except as it is called upon to adjudge the legal rights of litigants in actual controversies. Have the plaintiffs alleged such a personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult constitutional questions? This is the gist of the question of standing.

Brief Fact Summary:

An apportionment case may be reviewed on Fourteenth Amendment grounds, so long as these grounds are independent from political question elements.

Case Commentary:

Although cases brought under the Guaranty Clause historically are usually considered to be nonjusticiable, courts have tried to find alternate grounds for these claims that allow them to be considered. This trend shows that the scope of the political question doctrine is shrinking, although this may be tempered by increasingly strict limits on standing. The sequel to this case would come in 1964 with Reynolds v. Sims, when the Court articulated the principle of “one person, one vote” that would require many states to redraw the lines of their electoral districts and amend their constitutions. This applies to all states with bicameral legislatures. As a result, the process of creating districts has become extremely complex. In ensuring that each person’s vote has approximately the same power, counties and districts often overlap. Urban areas also received more power at the expense of rural areas.